United States
Environmental
November 198E
lector benera
Uton DC 204£
350R86001
Office of the Inspector General
Semiannual Report - —
to the Congress
April 1, 1986
through
September 30, 1986
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Foreword
The responsibilities of the Inspector General according to
the .Inspector General Act of 1978 are to promote
economy, efficiency, and effectiveness and to prevent
and detect fraud and abuse in Agency programs and
operations When I first came to the Environmental Protection
Agency,over 3 years ago, I established three primary goals for
the Office of Inspector General that, in fulfilling my
responsibilities under the IG Act, would be the most
constructive and beneficial to Agency management. I believe
the efforts by the Office of Inspector General this semiannual
period, along with the Agency's receptiveness to our work is a
testament-to the realization of these goals
My first goal was to improve the operation of the Office of
Investigations and promote the fullest possible compliance with
Federal laws and regulations By recruiting highly qualified staff
members, using sophisticated techniques, and concentrating on
high impact areas we have developed a potent investigative
force The number of successful prosecutive and administrative
actions along with the amount of fines and recoveries resulting
from our investigative efforts this semiannual period has more
than tripled compared to the period ending March 31, 1984
My second goal was to develop a thorough internal audit
program We emphasized the development of an internal audit
function that stresses timely and significant audits that assist
Agency managers to identify and correct ma|or systemic
problems For example, several of our most recent audits, as
described in this report, should result in changes in Agency
operations that will save millions of dollars while improving the
fulfillment of the Agency's environmental objectives Even with
shifting our resources to internal audits, we have also increased
the return on resources invested in external audits Since fiscal
1983, the amount of questioned costs sustained for recovery
has increased from under $6 to over $13 for every $1 spent
Finally, my third goal was to initiate a program to prevent
fraud, waste, and mismanagement Working jointly with
different components of the Agency through the suspension
and debarment program, the employee and public awareness
program, and the Committee for Integrity and Management
Improvement, we believe we have greatly influenced attitudes
and actions to prevent waste and abuse of scarce Agency
resources.
Support for the independent activities of the OIG by Agency
management has been laudable We look forward to working
with the Agency to continue our constructive relationship
promoting economy and efficiency in delivering a better
environment
U S Environmental Protection Agencjtohn C. Martin
u.o. JM1VJ.J.W Inspector Genera
Region 5, Library (5PL-16)
230 S. Dearborn Street, Room 16/V
Chicago, IL 60604
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Contents
Executive Summary 1
Profile of Activities and Results 3
Establishment of the DIG In EPA—Its Role and Authority 4
Organization and Staffing 4
Purpose and Requirements of the OIG Semiannual Report 6
Section 1—Significant Problems, Abuses, and Recommendations 7
Summary of Audit Activities and Results . 7
Agency Management 8
Construction Grants 13
Superfund Program 16
Section 2—Audit Resolution 19
Action Officials for Audit Reports Outstanding More Than Six Months 20
Previously Reported Items—Action Not Completed 20
Resolution of Significant Audits from Prior Periods 20
Section 3—Prosecutive Actions 21
Summary of Investigative Activity 21
Description of Selected Prosecutive Actions 22
Description of Selected Prosecutive and Administrative Actions
Concerning EPA Employees 24
Section 4—Fraud Prevention and Resource Management Improvements 25
Review of Proposed Legislation and Regulations 25
Suspension and Debarment Activities 27
Employee and Public Awareness Activities 29
Personnel Security Program 30
President's Council on Integrity and Efficiency 30
Hotline Activities 31
Professional Development . 31
Section 5—Delinquent Debts 32
Appendix—List of Audit Reports Issued. 33
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Executive Summary
Section 1—
Significant
Problems,
Abuses, and
Recommendations
1. Almost Half a Billion
Dollars Wasted on Faulty
Projects in Puerto Rico
After hundreds of millions of
Federal dollars were spent over
21 years, procrastination, poor
internal controls and lax
enforcement have prevented
Puerto Rico's wastewater
management programs from
achieving an acceptable level of
water pollution control (page
8)
2. Updated Penalty Schedules
and Better collection and
Followup Procedures Would
Increase the Effectiveness of
EPA's Mobile Source
Enforcement Program
Outdated penalty schedules and
inadequate negotiation
documentation, collection and
followup procedures reduced
the effectiveness of EPA's
enforcement of the Clean Air
Act (page 10)
3. EPA Managed Chesapeake
Bay Program Haphazardly
Monitoring and administration of
the grants and contracts valued
at $10 8 million was so poor
that less than 50 percent of the
required work products were
received or, if they were, the
Agency did not keep the results
Further, EPA could not
demonstrate how these various
research efforts benefitted or
even contributed to the Bay
cleanup (page 10)
4. Headquarters to Improve
Management of the Federal
Telecommunications System
(FTS)
EPA Headquarters procedures
and records used to monitor
long-distance telephone calls did
not comply with the Privacy Act
of 1974 nor enable the Agency
to identify and seek
reimbursement from those
making unofficial calls Annual
surveys to identify unneeded
equipment were not done for
fiscal years 1984 and 1985
(page 11)
5. Region 6, Texas, and
Oklahoma Mismanaged
Hazardous Waste Permitting
Activities
The Dallas Regional Office and
the States of Texas and
Oklahoma failed to manage and
control the Resource
Conservation and Recovery Act
(RCRA) permitting program to
ensure hazardous waste
facilities will be permitted or
closed within congressionally
mandated timeframes,
increasing the risk to human
health and the environment
(page 11)
6. Three EPA Locations Are
Not Properly Managing $9
Million of Property
Personal property with a total
estimated value of over $9
million in the Philadelphia
Regional Office, the Denver
Regional Office, and the
Environmental Services Division
offices in Wheeling, West
Virginia, and Annapolis,
Maryland, (ESD) is not properly
secured, loaned, stored, or
recorded Inadequate controls
render the property vulnerable
to conversion for personal use
or loss (page 12)
7. Poor Planning and Lack of
Project Coordination Resulted
in Grantees Claim for $3.9
Million of Ineligible or
Unsupported Costs
The Trinity River Authority of
Texas (TRA) claimed $2 4 million
of ineligible construction costs
The project did not conform to
sound management practices or
program requirements, resulting
in poor construction
coordination and ineligible
engineering design claims An
additional $1 5 million was not
accepted and referred to Region
6 for further evaluation (page
13)
8. Grantee's Startup Training
Program Fails Reasonabless
Tests
The startup training costs
requested by the City and
County of Honolulu under a
construction grant were
unreasonably high by more than
$1 million (page 13)
9. Ineligible Change Order and
Excessive Inspection Fees
Increase Claim by Almost
$880,000
The City of Hitchcock, Texas,
claimed $691,607 from a
change order for construction
costs not eligible for Federal
participation In addition, the
City claimed $188,202 in
excessive inspection costs
(page 14)
10. Grantee Claims Over
$840,000 of Ineligible Costs
The Delta Diablo Sanitation
District, California, claimed
almost $850,000 of ineligible
engineering and administrative
costs An additional $283,500 in
landscaping and legal costs
have been set aside pending
review of eligibility (page 14)
11. Grantee Claims $776,500 of
Ineligible and Unsupported
Costs
Anne Arundel County, Maryland,
claimed inelig ble costs of
$611,500 which did not comply
with EPA regulations including
over $252,000 previously
disallowed (page 14)
12. Grantee Claimed Over $1
Million of Ineligible,
Unsupported, and Contract
Overrun Costs
The Metropolitan Sanitary
District of Greater Chicago,
Illinois, claimed $733,800 of
neligible costs which were
outside the scope of the grant
or undocumented An additional
$295,000 of cost overruns were
set aside (page 15)
13. Grantee Claims Over
$650,000 of Unsupported
Costs on Oversized Project
The Town of Uxbndge,
Massachusetts, claimed
$516,658 of undocumented
questioned costs and an
additional $135,000 of
unapproved change orders and
miscalculated fees that were
set aside (page 15)
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14. City of New York Claims
Over $640,000 of Costs
Previously Disallowed
The City of New York claimed
costs totalling $641,470 for a
construction contract declared
ineligible by the New York State
Department of Environmental
Conservation (NYSDEC) In
addition, $641,662 was set
aside pending evaluation by the
Regional Administrator, Region
2 (page 15)
15. EPA Pays Excessive
Amounts for Emergency
Cleanups of Hazardous
Wastes
The urgent need for emergency
hazardous waste cleanups led
EPA to award multimillion dollar
contracts for Emergency
Response Cleanup Services
(ERCS) with limited competition
and without assurances that the
negotiated rates were
reasonable As a result, EPA is
paying excessive amounts for
the emergency cleanups (page
16)
16. EPA Is Not Collecting
Millions of Dollars Due from
Polluters
EPA was not always
aggressively pursuing the
recovery of hazardous waste
cleanup costs EPA did not take
action to recover approximately
$88 8 million from responsible
parties (page 17)
17. EPA Program Offices Need
to Improve Accounting for
Payroll Charges to the
Superfund
Several EPA regional and
Headquarters offices were still
not properly accounting for or
documenting payroll charges to
the Superfund appropriation
although this problem was
previously reported in a 1982
audit of the Trust Fund (page
18)
18. More Effective Monitoring
Needed of New Jersey
Cooperative Agreements
Almost $5 million of unneeded
Superfund cooperative
agreement funds were not
deobligated, only 20 percent of
remedial investigations were
completed on time, and, change
orders were approved without
assurance of required analyses
(page 18)
Section 2—
Audit Resolution
EPA management continues to
emphasize both timeliness and
quality of audit resolution As a
result of emphasis on the audit
resolution process by both EPA
and the Office of Inspector
General, the level of overdue
audits hit an all time low during
the past 6-month period The
number of overdue items
decreased from the 21 reported
last period to 18 as of
September 30—down 14
percent During this period, EPA
management closed 773 audits
and sustained $31 7 millions of
questioned costs, including
$27 5 million for cost recovery
and $4 2 million in cost
reductions
EPA also recovered $3 8
million in cash collections and
$127 million in offsets against
billings from resolution of audits
from prior and current periods
As a continuing effort to
improve the audit resolution
process, four special task force
projects from last year's
National Audit
Resolution/Assistance Disputes
Conference held in Atlanta have
been completed Steps are
underway to implement the
recommendations of these task
forces—all of which will further
improve the quality of the
Agency's audit resolution
functions
A special review disclosed
that recoveries are substantially
less than the Agency agreed to
recover In addition, thorough
analysis of this situation is
prevented since the Agency
Financial Management
Division's tracking reports
contain numerous inaccuracies
and are ineffective to control
this function An example of
errors include $75 8 of $186 8
million of sustained costs which
should have been tracked on
the reports but were not
Therefore, many millions of
dollars of audit benefits were
not identified as Agency accom-
plishments The OIG
recommended that the
Comptroller provide instructions
emphasizing the importance of
accurate reporting Further, we
recommended that reviews
periodically evaluate these
activities and procedures be
implemented for controlling
receivables and collections
Corrective action has already
been taken on several of these
issues (page 19)
Section 3—
Prosecutive Actions
During this semiannual reporting
period our investigative effort
resulted in a continuing increase
in the number of prosecutive
and administrative actions Our
ongoing investigations of bid
rigging has resulted in 36
indictments and 24 convictions
as of September 30, 1986 The
number of prosecutive and
administrative actions along
with the amount of fines and
recoveries resulting from our
investigative effort in fiscal 1986
has more than doubled from the
amounts reported for fiscal
1985
As a result of an investigation
reported in our prior semiannual
report, Brian Ingber, Supervisor
of Fallsburg, New York, was
convicted for the second time
and Wayne Pirnos, a State
official, was convicted in
connection with an EPA-funded
project In another case, two
contractors conspiring to rig
bids on a Philadelphia water
project were convicted and
fined $375,000 Two more
electrical contractors were
convicted and fined $900,000
for rigging bids on a
Chattanooga project Other
investigative cases involved
embezzlement of grant funds by
a former EPA employee and a
county official, and a former
EPA purchasing agent who
founded and operated a
business to which he directed
EPA contracts (page 21)
Section
Fraud Preventioi
and Resources
Management
Review of Proposed
Legislation and Regulatio
During this period we revie
32 legislative and 87 regulc
items, a 70 percent mcreas
over the previous semianni
period The most significan
items reviewed included dr
legislation on proposed1
amendments to the False
Claims Act, the Financial F
Detection and Disclosure A
1986, the Program Fraud C
Remedies Act of 1986, anc
Intergovernmental Fmancm
of 1986, Federal Acquisitio
Regulation on Fraud, Wast<
and Abuse, and the need f
criminal penalties in the ex
Clean Air Act (page 2E)
Suspension and Debarrm
Activities
During this semiannual rep
period the number of
debarments, voluntary
exclusions, settlements, ar
suspensions to deny or res
persons or firms from
participating in EPA prograi
operations because of poo
performance has mcreasec
the fifth consecutive time
of these actions are relatec
our bid rigging mvestigatioi
and efforts by the Minnesc
Attorney General's office (|
27)
Personnel Security
As one of the Agency's fir:
defenses against fraud, us
background mvestigat ons
review the integrity of EP£
employees and contractors
Personnel Security staff
reviewed 71 percent more
cases this semiannual pern
than last, eliminating its
inherited chronic backlog I
identified several condition
resulting in administrative
actions to protect EPA's
interests (page 30)
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Profile of Activities and Results
Environmental Protection Agency
Office of Inspector General
April 1, 1986, to September 30, 1986
Fiscal 1986
Audit Operations
• Questioned Costs*-Total (expenditures which OIG
finds are not allowable)
• Set-Aside Costs*-Total (expenditures which are
insufficiently supported to determine their allowability)
• Sustained Costs for Recovery and Savings-Federal
Share (costs which EPA management agrees are
unallowable and is committed to recover or offset
against future payments)
• Cost Efficiencies or Deobligations (funds made
available by EPA management's commitment to
implement recommendations in OIG internal and
management or preaward audits)
• Recoveries from Audit Resolutions of Current and
Prior Periods (cash collections or offsets to future
payments)**
• EPA Audits Performed by the OIG
• EPA Audits Performed by Another Federal Agency,
State Auditors, or Independent Public Accountants and
Attachment P Audits
• Audit Reports Resolved (agreement by Agency
officials to take satisfactory corrective action)
Investigative Operations
• Fines and Recoveries
• Investigations Opened
• Investigations Closed
• Indictments of Persons or Firms
• Convictions of Persons or Firms
• Administrative Actions Taken Against EPA Employees
Fraud Detection and Prevention Operations
• Debarments, Suspensions, Voluntary Exclusions, and
Settlement Agreements (actions to deny persons or
firms from participating in EPA programs or operations
because of misconduct or poor performance)
• Hotline Complaints Received
• Hotline Complaints Processed and Closed
• Proposed Legislative and Regulatory Items Reviewed
• Personnel Security Investigations Adjudicated
S 57 7 million
$1066 million
$ 27 5 million
83
705
773
74
30
30
119
589
$110 1 million
$2085 million
$ 70 million
$ 4 2 million $ 25 7 million
$ 16 5 million $ 25 5 million
155
1,420
1,617
1 9 million
151
201
27
28
40
$ 2 8 million
336
420
41
39
71
144
57
54
189
934
* Questioned and set-aside costs are subject to reduction pending further review in the audit
resolution process
** Information on recoveries from audit resolution is provided from the EPA Financial Management
Division and is unaudited
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The Inspector General Act of
1978 (P L 95-452) created
Offices of Inspector General to
consolidate existing
investigative and audit
resources in independent
organizations headed by
Inspectors General
EPA established its Office of
Inspector General (OIG) in
January 1980 As an agency
with a massive public works
budget, EPA is vulnerable to
various kinds of financial
abuses The OIG's role is to
review EPA's financial
transactions, program
operations, and administrative
activities, investigate allegations
or evidence of possible criminal
and civil violations, and promote
economic, efficient, and
effective operations within the
Agency The OIG is also
responsible for reviewing EPA
regulations and legislation
The EPA Inspector General
reports directly to the
Administrator and the Congress
and has the authority to
• Initiate and carry out
independent and objective
audits and investigations,
• Issue subpoenas for evidence
and information,
• Obtain access to any
materials in the Agency,
• Report serious or flagrant
problems to Congress,
• Select and appoint OIG
employees, and
• Enter into contracts
The Inspector General is
appointed by, and can be
removed only by, the President
This independence protects the
OIG from interference by
Agency management and allows
it to function as the Agency's
fiscal and operational watchdog
Organization and
Staffing
The Office of Inspector General
functions through three major
offices, each headed by an
Assistant Inspector General
Office of Audit, Office of
Investigations, and Office of
Management and Technical
Assessment
Nationally, there are six
Divisional Inspectors General
Audit and five Divisional
Inspectors General for
Investigations who dired staf
of auditors and investigators ;
who report to the appropriate
Assistant Inspector General ir
Headquarters
Staffing Distribution—Fiscal 1986 Ceiling
Office Headquarters Field
Total
Inspector General
Audit
Investigations
Management and Technical
Assessment
5
33
8
23
5
140 173
52 60
23
Total
69
192
261
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Office of Inspector General - Who's Who
Headquarters
Ernest E Bradley III
Assistant Inspector General
Kenneth A Konz
Deputy
Steven A McNamara
Director
James 0 Rauch
Director
1
of Audit
Inspector General
Deputy Inspector General
Office of Investigations
John C. Martin
Donald E. Kirke
1
Office of Ma
and Tec
Assess
Operations Staff
Technical Services Staff
John E Barden
Assistant Inspector General
Daniel S Sweeney
Deputy
Anna M Virbick
Assistant Inspector General
Technical Assessment
and Fraud Prevention
Division
Administrative and
Management Services
Division
John C Jones
Director
Edwin N Canady
Director
Divisional Inspectors General
Region 5
Antnonv C (.,;H r<_ 'in Au'j
Region 8 (audit), 9, & 10
Fi j";kir R Be"Ut i Aji;,'
> RK hrird W.icjrif-r ''->M'stiq ru.1
Region 1 & 2
Pcjul VrKi'J, '
Robi r' M BvT
Region 3
Pd Li « G. "I-
Wl' ,1'Tl \ Ci 1
..M ,'|C) II " '
Headquarters
Kerrrth H.JLM-
ntt"n,.| A, ! ;
Region 4, 6, 7, & 8
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Purpose and
Requirements of
the Office of
Inspector General
Semiannual Report
The Inspector General Act of
1978 (P L 95-452) requires the
Inspector General to keep the
Administrator and Congress fully
and currently informed of
problems and deficiencies in the
Agency's operations and
recommend corrective action
The IG Act further specifies that
semiannual reports will be
provided to the Administrator by
each April 30 and October 31,
and to Congress 30 days later
The Administrator may transmit
comments to Congress along
with the reporl, but may not
change any part of the report
The specific reporting
requirements prescribed in the
Inspector General Act of 1978
are listed below Also included
are additional requirements
resulting from Senate Report
96-829 on the Supplemental
Appropriations and Rescission
Act of 1980 (PL 96-304)
Source
Section and Page
INSPECTOR GENERAL ACT 25
Section 4(a)(2), Review of Legislation and 4
Regulations
Section 5(a)(1), Significant Problems, Abuses, 1 7
and Deficiencies
Section 5(a)(2), Recommendations with 1 7
Respect to Significant Problems, Abuses, and
Deficiencies
Section 5(a)(3), Prior Significant 2 20
Recommendations on Which Corrective Action
Has Not Been Completed
Section 5(a)(4), Matters Referred to 3 21
Prosecutive Authorities
Section 5(a)(5), Summary of Instances Where *
Information Was Refused
Section 5(a)(6), List of Audit Reports Appendix 33
SENATE REPORT 96-829
Senate Report, Page 11, Resolution of Audits 19
Senate Report, Page 12, Delinquent Debts 5 32
* There were no instances where information or assistance requested by
the Inspector General was refused during this reporting period According!/,
we have nothing to report under section 5(a)(5) of the Inspector General Act
of 1978
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As required by sections 5(a)(1)
and (2) of the Inspector
General Act of 1978, this
section identifies significant
problems, abuses, and
deficiencies relating to the
Agency's programs and
operations along with
recommendations for the
current period. The findings
described in this section
resulted from audits and
reviews performed by or for
Office of Audit and reviews
conducted by the Office of
Investigations. Because these
represent some of our most
significant findings, they
should not be considered
representative of the overall
adequacy of EPA
management. Audit findings
are open to further review but
are the final position of the
Office of Inspector General.
This section is divided into
four areas: Summary of Audit
Activities and Results, Agency
Management, Construction
Grants, and Super-fund.
Summary of
Audit Activities
and Results
Questioned and Set Aside Costs by Type of Audit
[90
•80
•70
r60
-50
Set-Aside Costs
Questioned Costs
Construction
Other Grants
& Contracts
Superfund
Internal &
Management
Distribution of Audit Effort by Staff Days
Distribution of Audit Reports Issued by Source
External—
Grants/Contracts
8250
44 9%
State Auditors
21
2 7%
Independent
Public Account
112
142%
Other Federal Agency
292
37 1 %
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Agency
Management
The Inspector General Act
requires the OIG to initiate
reviews and other activities to
promote economy and
efficiency and to detect and
prevent fraud, waste, and
EPA Fiscal 1986
Operations/Resources Profile
Agency
Management
689,249
21 6%
mismanagement in EPA
programs and operations
Internal and manage- merit
audits and reviews are
conducted to accomplish these
objectives largely by evaluating
the economy, efficiency, and
effectiveness of operations
The following are the most
significant internal and
management audit and review
findings and recommendations
Other Grants/Contracts
794,298
9%
Superfund
206,163
65%
Construction
1,500,000
47 0%
Total = $3,189,709,000
($s in thousands)
Almost Half a
Billion Dollars
Wasted on Faulty
Projects in Puerto
Rico
Problem
After hundreds of millions of
Federal dollars were spent
over 21 years, procrastination,
poor internal controls, and lax
enforcement have prevented
Puerto Rico's wastewater
management programs from
achieving an acceptable level
of water pollution control.
This map identifies the locations
of the project sites considered
Background
EPA and its predecessor
organizations have obligated
more than $500 million in grants
and direct funding to tie Puerto
Rico Aqueduct and Sewer
Authority (PRASA), the Puerto
Rico Environmental Quality
Board (EQBl and the Army
Corps of Engineers (COE)
These funds were to be used
for water gualr.y management,
the planning, design, and
construction of wastewater
treatment systems, and
construction management and
nspection The signing of a
grant award is a declaiation by
the grantee that it possesses
the financial capability to
construct, operate, and maintain
a treatment facility throughout
the life of the facihty
We Found That
Of the $500 million,
approximately $400 mill on v\
awarded for construction of
regional wastewater treatme
systems Five of the system
that together cost over $200
million were still not operatic
and were rusting away Five
other regional systems whicl
had received EPA funding fo
planning as long ago as 197^
have had little or no
construction PRASA has
estimated that an additional
$800 million (including $600
million of its own funds) will
needed to complete priority
construction projects, achiev>
full compliance with EPA
regulatory requirements at al
PRASA facilities, and elinmna
all its current existing liability
in excess of available current
assets PRASA lacked the
managerial and technical
capability required to acnieve
effective operations,
maintenance, and comphanc'
with regulatory provisions an
EPA National Pollutant
Discharge Elimination Syster
(NPDES) permits
PRASA's Financial Proble
PRASA did not have an
acceptable accounting syster
which would properly identif
and support costs incurred
under construction projects c
serve as an appropriate basu
identifying and allocating of
indirect costs PRASA freque
failed to demonstrate adequc
financial capability to pay the
non-Federal share of
OCEANO ATLANTIC
MAR
CAR/BE
• Plantas de Tratamienlo Regoiwles
A Plantas de Tratamiento I ocjles
-------
construction grant funded
projects Additionally, we found
that PRASA was in grave
f'nancial condition Our review
of the PRASA 1984 and 1985
audited financial statements
disclosed that PRASA's net
revenue had decreased 280
percent from Fiscal Year 1983
to Fisca! Year 1985, while Is
long-term debt had increased by
.'3 percent for the same penod
r'RASA proiected a $2 7 million
average monthly shortfall for
Kcal 1986
PRASA's Failure to Comply
with Consent and
Administrative Orders. PRASA
''ailed to comply with provisions
)! tho United States District
Court Consent
(irders and EPA issued
Administrative Orders for over
"0 years All such orders
addressed corrective actions
necessary to eliminate the
continuing violations of
provisions of the Clean Water
ACT iCWAi and NPDES permits
We also noted that cond'tions at
Pueito Rico's wnstewater
treatment plants appeared to
1-1 ive worsened since the
inpointnient of a Court Monitor
- '980
Reg'on 2 had allowed
•'RASA's noncomphance with
CWA and NPDES oeimits to
••opt.nuc througr its decision to
extend negotiations rather tr,,m
ujrsup effective enfcrcement
action,. The District Court and
the Umted State-, Attorney'-;
(,'ffiof- hao stated then concern
'eqarding E ;;|A s apparent
• luctrince to undertake force ul
actions to achieve compliance
.vth Consent Orders issued bv
'he Court
PRASA's Operational and
Maintenance Deficiencies. Tie
Court Monitor had documented
NASA's unsatisfactory
performance at a majority of
!' e>r waste water treatment
facilities Almost 50 percent of
rjRASA s operable facilities
jnder the Court Order were
overloaded, and approximately
90 percent either were in
."Oladon of NPDES permits,
lacked necessary permanent
sludge management systems
Jr were in poor physical
operational condition The OIC
verified the findings of the Court
Monitor and identified
significant facility deficiencies as
shown by the pictures
The Court Monitor also
identified significant deficiencies
in sampling and analysis reports
for over 99 percent of PRASA'^
facilities The numerous
operational and maintenance
deficiencies disclosed were
known to have resulted in the
discharge of inadequately
treated wastes from PRASA ^
wastewater treatment facility
Some of these effluent
discharges were in close
proximity to intakes for drinking
water facilities DocumentnK>';
ndicated excessive levels ot
waterborne pathogenic
organisms (viruses, bactera
parasites) were present in
surface waters A Decent study
completed IP January 1986 has
linked contamination of drinking
water supplies with improperly
treated effluent and found that
the effluent may be a primary
cause for public health
epidemics m Puerto Rico smne
1976
We Recommended That
Because we believe Region 2
must be held directly
accountable for ensuring 'hat
PRASA's problems are
corrected, we recommended
that Region 2 be required to
carefully monitor, track and
report on the progress and
success of oorrect've action--.
be'ng taken n response to t'- '-
report Resoonsible
Headquarters off uals should
track overa'l regiona
accomplishments If appropriate
progress is not made, EPA
should transfer responsilj^'t, tor
managing PRASA's progi i" s to
Headquarters and, f nect," >)'v
cut off additional financ, a
support to PRASA unt.l
necessary improvements navt-
been completed
What Action Was Taken
The audit repon was issued to
the Administrator on August 28,
1986 A response to the audit
report is due or, Novembei 78,
1986
The Agency's response to the
draft report stated that both
Headquarters and Region 2
wastewater management and
compliance programs recognize
many of the problems outlined
in our repon However, in the
Agency's opinion, the problems
are more complex and difficult
to resolve than described in our
report During the past year,
EPA has followed a strategy of
providing assistance to PRASA
which increases the likelihood
of eventual compliance EPA
will immediately implement a
series of management initiatives
to build on the improvements
seen in the past year
PRASA's pioqress toward
compliance with the terms of
the Consent Order wil1 be
carefully monitored by
Headquarters and Reckon ?.
with the Administrator being
apprised of th;s prc.qn- ss on at
least a quartrhy b,r is F PA ,s
cautious'v opt>misii<> that
PRASA iv '< ' ',"t'M;r to improve
its Tifi'i'iQf"'.(";( ,j'i,l rjoeAflf/i'"S
of Puerto /•?•• o s wastr-watei
treatment Diagram Should (/,•,
optimism prcx.e u- \viranted,
EPA stands rr-idv to Cake even
stronger Kten-. to ensure
compliance with judicial orders
and the regalements of the
Clean Water 4c'
Examples of Operational and
Maintenance Deficiencies at
PRASA Facilities
Although the Agency has
promised to take stronger
steps, we have not seen
evidence of it f-or example the
District Court, at the request of
Region 2, issued an Interim
Order on March 11, 1986,
which directed PRASA to
submit vanous proposals within
7b days After 30 days of
review of this submission, the
Region has requested that
another 60 d.iys be granted to
continue negotiations
Considering ihis enforcement
act/on began last November,
one might conclude that FPA is
simply corif" iiinq its previous
pattern o* pfctr.icted
neaotiations ->nd numerous
pii'is We / not be'it'Vf; that
si,- h delays should be allowed
-------
Updated Penalty
Schedules and
Better Collection
and Followup
Procedures Would
Increase the
Effectiveness of
EPA's Mobile
Source
Enforcement
Program
Problem
Outdated penalty schedules
and inadequate negotiation
documentation, collection and
followup procedures reduced
the effectiveness of EPA's
enforcement of the Clean Air
Act.
Background
EPA's Office of Mobile Sources
(OMS) is responsible for
enforcing Title II of the Clean Air
Act, which requires the
reduction of air pollution from
motor vehicles
When violations by gas
stations such as those
concerning nozzle size or lead
content are found, OMS issues
a Notice of Violation, including a
proposed penalty Proposed
penalties may be reduced if the
respondent acts promptly to
correct the violation, prevents
future violations, corrects
environmental damage, or
performs alternative projects
with sound environmental
benefits
We Found That
Proposed penalties for violations
have not changed since 1975
and are in some cases only 5 to
10 percent of the amount
allowed by the Clean Air Act
Penalties currently in place (1)
were not always commensurate
with the amount of
environmental damage resulting
from the improper use of leaded
fuel in vehicles which require
unleaded fuel and (2) do not
sufficiently deter large-sized
companies from violating the
Act
10
Effective procedures were not
in place to ensure that each
violator paid an appropriate
penalty Although OMS had
initially proposed more than $46
million in penalties over the last
three years, only $4 million in
cash had been collected This
occurred because
• OMS routinely reduced
penalties up to 40 percent if
violators promptly corrected the
violation and established
appropriate programs to prevent
their recurrence OMS records
in such cases frequently did not
document that these reductions
were warranted
• OMS routinely reduced the
proposed penalties even further
by accepting alternative projects
in lieu of cash OMS lacked
specific criteria for reasonably
quantifying the credit to be
given or for evaluating the
environmental benefits of
alternative projects
• After final penalties and
alternative projects were
accepted, OMS did not always
ensure that violators actually
paid the cash penalties or
complied with additional
settlement conditions
In addition, the Agency did
not forward information to the
Internal Revenue Service
concerning penalties paid or
violators' expenditures on
required alternative projects
OMS also did not assess
penalties of $1,765,000 because
it did not pursue violations of
the lead phasedown regulations
This resulted from unclear
procedures for pursuing
penalties against small
refineries
We Recommended That
The Assistant Administrator for
Air and Radiation
• Work closely with the
Assistant Administrator for
Enforcement and Compliance
Monitoring to revise the 1975
penalty structure to raise
penalty amounts,
• Improve procedures to
ensure all reductions in
penalties are supported,
• Develop criteria and examples
in the OMS Civil Penalty Policy
for staff to follow when
accepting and assigning credit
for alternative projects;
• Move quickly to implement
adequate procedures for
tracking payment of cash
penalties;
• Establish compliance
milestones for cases with
alternative settlement conditions
and forward penalty information
to the Internal Revenue Service,
and
• Develop clear procedures for
pursuing lead phasedown
violations
What Action Was Taken
OMS officials acted promptly to
implement some of our
recommendations Our report
was issued on September 30,
1986, to the Assistant
Administrator for Air and
Radiation A response to the
report is due on December 29,
1986
EPA Managed
Chesapeake Bay
Program
Haphazardly
Problem
Monitoring and
administration of the grants
and contracts valued at $10.8
million was so poor that less
than 50 percent of the
required work products were
received or, if they were, the
Agency did not keep the
results. Further, EPA could
not demonstrate how these
various research efforts
benefitted or even
contributed to the Bay
cleanup.
Background
The Chesapeake Bay
Agreement in December 1983
formalized a long-term
commitment by the Federal
Government, the States of
Maryland, Virginia, and
Pennsylvania, and the District of
Columbia to prepare and
implement a coordinated plan to
restore and protect the waters
and the living resources of the
Bay
Accepted
36
40 0%
As part of its continuing
efforts to stop the slow deatf
of the Bay, EPA awarded $2E
million for 102 grants and
contracts during fiscal years
1978 through 1984 We
selected 23 of these grants a
contracts, totalling $108 miNi
and requiring 90 work produc
for detailed review
We Found That
EPA did not follow its own
regulations and procedures fc
monitoring grants and contrac
Work products required by
these grants and contracts w>
either not completed or could
not be found In a number of
instances, EPA was not awan
that the work products were
even missing During oui
review, we found that only 4^
out of 90 work products were
located by EPA personnel anc
only 36 of these were accept
From this, we have concludec
that EPA's planning was
deficient because the work
products were evidently not
needed However, if some or
of these work products were
needed, then the techni- cal
aspects of the Bay program
become suspect Also, work
products received months or
years after the original
completion dates appear to b<
of question- able value The
following are examples
disclosed during the audit
• One contract required 16
work products including 11 ta
reports, draft and final reoorts
on the Bay Circulation Model,
and training workshops The
contractor believed that EPA
"abandoned" his project, rath'
than fund an additional $35,2C
requested by the contractor tc
complete the contract scope c
work As a result, EPA spent
$580,000 to date on a 4-vear
contract that produced only or
draft report which was rejecte
by EPA
90 Work Products Required
Rec'd/Not Accet
3
.9%
Not Located
46
51 1%
-------
• A grant was awarded in
August 1978 to develop a water
quality laboratory and conduct a
study evaluating helicopter
sampling versus boat sampling
An EPA geochemist who
reviewed the grantee proposal
commented that " the
proposal is relatively naive and
has much to be desired As
far as this proposal offering
anything new to the present
array of monitoring labs and
programs on the Bay, it does
not " Despite serious quest ons
concerning the benefit and
relevance of the project, EPA
has spent over $300,000 on the
project
• Final reports were required by
each of two grants awarded for
$733,393 and $742,434 EPA
never received these reports
and the grantees claimed that
they were unaware such reports
were required We also found
that only 5 of the required 24
semiannual progress reports
were available at the grantee's
offices
• A grantee was awarded three
grants amounting to $320,014,
each grant requiring a final
report After issuance of our
draft report, EPA officials found
one report and contended that it
was the only one required for all
three grants However, the
grantee confirmed to us that
three reports were, in fact,
required He presented us with
the second final report, and a
third preliminary draft report
which he indicated would be
finalized in early 1987 The third
report was due to EPA in final
form in March 1982
In addition, we found that
project files were incomplete
and maintained haphazardly The
project files did not contain
justifications for funding
increases totalling $2 8 million
applicable to the grants and
contracts included in our
review, as such, EPA cannot
currently document that these
funds were spent for valid
reasons Completed grants and
contracts were not closed
Adequate work programs were
not available for our review, nor
was there evidence that
numerous grant conditions were
satisfied Further, project files
were destroyed without proper
authority instead of sending
them to the Federal Records
Center for proper storage when
the grant was closed
We Recommended That
The Regional Administrator,
Region 3
• Determine the status of work
products associated with all
grants and contracts awarded
under the Chesapeake Bay
Program and recover funds from
grantees and contractors, if
appropriate
• Assure that procedures for
monitoring grants and contracts
are fully implemented
• Strengthen administrative
procedures and take immediate
action to obtain the necessary
documentation to close grants
and contracts
What Action Was Taken
The draft audit report was
issued to the Regional
Administrator on June 24, 1986
The Regional Administrator and
his staff agreed with our
recommen- dations They
acknowledged that a serious
administrative problem exists
but disputed various facts The
final audit report was issued on
September 24, 1986 A formal
response is due on December
23, 1986
Headquarters to
Improve
Management of
the Federal
Telecommunicatio-
ns System (FTS)
Problem
EPA Headquarters procedures
and records used to monitor
long-distance telephone calls
did not comply with the
Privacy Act of 1974 nor enable
the Agency to identify and
seek reimbursement from
those making unofficial calls.
Annual surveys to identify
unneeded equipment were
not done for fiscal years 1984
and 1985.
We Found That
In 1981, Headquarters
implemented telephone cost
accountability procedures to
identify and collect for unofficial
long-distance calls billed to the
Agency This improved the
Agency's ability to control
long-distance costs The
procedures resulted in records
which were used to identify
individuals who made unofficial
calls Therefore, the records
appeared to be subject to the
Privacy Act of 1974, which was
passed to safeguard individuals
from the misuse of Federal
records and allow individuals to
review records maintained
about them Agency procedures
in regard to these records did
not, however, comply with the
Act Consequently, they needed
to be changed unless a
determination was made that
the Act did not apply
Individuals at Headquarters
made long-distance calls for
unofficial purposes in violation
of 31 USC 1348(b) and
Agency directives Headquarters
paid an estimated $71,000 for
unofficial calls made during the
first quarter of fiscal 1985 but
collected only $2,900
In addition to incurring costs
for improper phone use,
physical inventories of the
telephone lines and equipment
and the related annual needs
survey, required by regulations
and an Agency directive, were
not performed for 1984 and
1985 Limited reviews by the
Office of Information Resources
Management (OIRM) identified
unneeded equipment, including
several hundred telephone lines
We Recommended That
The Director, Office of
Information Resources
Management (1) clarify the role
of Headquarters offices in
monitoring telephone use and
determining equipment needs,
(2) expand its system for
monitoring long-distance tele-
phone use, and (3) educate
individuals about proper
telephone use
What Action Was Taken
In comments on the draft audit
report, the Director, OIRM,
described various actions
underway or planned to correct
the conditions we found Of
primary importance, the
telephone accountability
procedures and records will be
changed to comply with the
Privacy Act The Director's
response to our audit report,
issued on June 17, 1986,
indicated that the corrective
actions were generally on
schedule
Region 6, Texas,
and Oklahoma
Mismanaged
Hazardous Waste
Permitting
Activities
Problem
The Dallas Regional Office
and the States of Texas and
Oklahoma failed to manage
and control the Resource
Conservation and Recovery
Act (RCRA) permitting
program to ensure hazardous
waste facilities will be
permitted or closed within
congressionally mandated
timeframes, increasing the
risk to human health and the
environment.
Background
A major objective of EPA's
National Permits Strategy is to
issue permits to all land disposal
facilities by the end of 1988 and
all incinerator facilities by the
end of 1989 RCRA was
designed to ensure that the
mismanagement of hazardous
waste does not continue EPA
has identified the permitting of
hazardous waste management
facilities as the key to
implementing the regulations
since permits identify the
administrative and technical
performance standards to which
facilities must adhere
We Found That
Improvements were needed in
the permitting program in
Region 6 to ensure the
protection of the public and the
environment from the improper
management of hazardous
waste
11
-------
Key elements identified by
EPA in order to have a
successful permit program were
either missing or not fully
implemented by Region 6 and
the States of Texas and
Oklahoma Deficient or missing
elements included lack of
exposure information for
releases of hazardous wastes,
land disposal permit applications
which were not submitted,
permitting time-frames which
were not met, and two States
that had no EPA on-site
reviews As a result, the
potential is greater for
mismanagement of hazardous
waste which threatens human
health and the environment
Region 6, Texas, and
Oklahoma did not perform joint
site visits to assist facilities in
completing permit applications
This failure delayed the permit
process and impedes the effort
to minimize the release of
hazardous waste into the
environment
Region 6 did not effectively
prioritize facilities for permitting
because the Region has made
little effort to assist the States
determine the most
environmentally significant
facilities
The Hazardous Waste Data
Management System (HWDMSi
did not provide management
with accurate information on the
number of facilities requiring
permits, planning to close or
the current status of laoh'ies
Texas and Oklahoma nnd not
fully developed a program for
early and expanded public
involvement in decisions for
permitting facilities that affect
public health and the
environment
We Recommended That
The Regional Administrator,
Region 6, take action to ensure
• Exposure information and
permit applications for land
disposals are submitted as
required, permitting timeframes
are met, and on-site reviews are
made in all States,
• States comply with EPA's
requirement for joint site v.-iis
to assist facilities ir subnrtt'ncj
complete permitting
applications,
• The Region's RCRA
permitting and enfcrcemem
staff become active participants
with the States in implementing
the Facility Management
Planning approach to permit ng
hazardous waste facilities,
• Region 6 -eview the HWDMS
for errors and omissions a>v.
maintain the system on a
correct, accurate and comj. lr>tc
basis, and
• Region 6 and the States
develop and .implement a public
involvement program that
allows citizens to become
involved w.th perm ttmg
decisions
What Action Was Taken
The fina1 aud't repo/1 v\>8->
issued on Sepfe/^b ?' A-' "9'.6
A 'csponse ;c tnt; r^poi' :- :; .<>
o^ Deccmhe' }}, 1')86 fi'ti/ i
6 officials ha.'e -Aated ".,:' ;/)• >
bsl'eve planned actions '>vi<: '">'P
correct the deficiencies
fiadre^sed "i t/.e rii, /'* vn:e tj.L i n t(.
recover njmer('_s items lost 01
stolen
vVithir ESD d!t proper
va'ued at $252,300 was no-
identified and excess property
valued at $159 QUO was noi
disposed of pri. pcrty loaned '.<
ot'ier rederal and ion l eder i
entities was no^ :o:~ trolled, anrl
ven'cles were i1 excess ut
cu'T.rt requ.remi'""-
We Recommended That
The Region-!1 AJm niitralor^
Regions 3 and d, imurjve ffie i
property man?(|ei •'"'! ;vstt:m-
bv '
• Timely recoioinc all mcom'nr]
pj";ii,ise^ ,ind J.^pcsi' nn ,
• Jorfor:>: ng "inni a1 p^vsi' a
iriVt~n''Kies and rfxoncil rg
ro;,jlt'- to property :ecor'K,
• F jilnWi'KJ p.OCSd.l'H'- '0'
cornro:ling loar'<.t. 'die -i"J
exces:- properv, and
• Appointing custodial ol'^e's
and updating ; ppo rtmei is
regulatly
What Action Was Taken
The audit report on Region 3's
Property Management System
was issued on September 2,
1986 A response is due on
December 1, 1986 which
identifies and schedules the
specific actions completed anc
planned to be completed dunn
the next 9 months A forma!
resoonse to the audit report is
due by December 22, 1986
The ESD audil report was
issued to the Regional
Administrator, Region 3, ori
August 26, 1986 Regional
representatives agreed with th
recommendations in the draft
repon and have initiated action
to r:o"~e<:! the deficiencies
aiscJosed during our review A
response to the report is due L
November 26, 1986
12
-------
Construction
Grants
EPA's wastewater treatment
works construction grants
program is the largest single
program the Agency
administers Under the
provisions of P L 92-500, as
amended, the Agency is
authorized to make grants
covering up to 75 or 85 percent
of the eligible costs of
constructing wastewater
treatment facilities Through
September 1986, $2 1 billion
was obligated on 428 new
grants and 959 amendments to
existing grants this fiscal year
The construction grants program
represents 44 percent of EPA's
total fiscal 1986 budget As of
September 30, 1986, EPA had
2,602 active construction grants
representing $152 billion of
Federal obligations
Poor Planning and
Lack of Project
Coordination
Resulted in
Grantee's Claim for
$3.9 Million of
Ineligible or
Unsupported Costs
Combined Trinity River Authority audit
profile
Problem
The Trinity River Authority of
Texas (TRA) claimed $2.4
million of ineligible
construction costs. The
project did not conform to
sound management practices
or program requirements,
resulting in poor construction
coordination and ineligible
engineering design claims. An
additional $1.5 million was
set aside and referred to
Region 6 for further
evaluation.
We Found That
TRA had been awarded two
grants totalling $29 9 million for
the design and expansion of a
regional sewage system that
included the construction of
relief interceptors We
guestioned $2 4 million
consisting of
• $1 2 million paid by the
grantee to the construction
contractor resulting from the
grantee's changes in design,
poor construction coordination
with other contractors, and late
issuance of work orders,
• $962,000 of construction
costs not approved by change
order for extra work items,
items already covered by the
basic construction contract, and
for correcting problems that
should have been covered by
warranty,
• $51,000 of normal operating
and maintenance costs for
repair and cleaning lines, and
• $188,000 for ineligible
engineering, unapproved force
account work, ineligible
construction, and an unapproved
flood damage investigation
In addition, approximately
$1 5 million was set aside
because TRA had not followed
EPA procurement regulations in
obtaining engineering services
and had claimed indirect costs
that had not been included in
the grant awards
We Recommended That
The Regional Administrator,
Region 6
• Not participate in the Federal
share of questioned costs ($1 8
million),
• Determine the eligibility of
set-aside costs referred to EPA
for review, and
• Recover the applicable
amount, after the above
recommendations are complied
with
What Action Was Taken
Final audit reports were issued
on both grants For one, issued
July 25, 1986, a final
determination letter was issued
on September 29, 1986, by
Region 6, sustaining the Federal
share of questioned costs
($517,000) The set-aside costs
($138,000) were determined
allowable For the other, issued
August 21, 1986, Regional
action is due by November 21,
1986
Grantee's Startup
Training Program
Fails
Reasonableness
Tests
Problem
The startup training costs
requested by the City and
County of Honolulu under a
construction grant were
unreasonably high by more
than $1 million.
We Found That
A $1 2 million grant was
awarded to the City and County
of Honolulu for startup training
services at its wastewater
treatment plant The grantee,
desiring a permanent, ongoing
training facility, pro|ected a
1,730 staff day requirement
valued at about $1 3 million
EPA guidelines provide up to a
maximum of 300 days, at a cost
of $138,000
Also, the second most
qualified applicant was awarded
the startup training contract,
without proper justification
Further, the startup training
contractor billed the EPA
construction grant for ineligible
costs, mclud'ng those for
transporting family members
between the U S mainland and
Hawaii
We Recommended That
The Regional Administrator,
Region 9
• Perform a technical review of
the startup training services and
establish reasonable amounts to
be funded under the grant In
no event should the approved
services exceed the 300 staff
days provided under the existing
regulations
• Recoup any grant funds
reimbursed in excess of the
amount established by the
Region's technical review
• Require the grantee to
provide a written justification for
selecting a firm other than the
most qualified firm If
procurement irregularities are
found, the Region should
consider invalidating the startup
training contract
• Require the grantee to
improve its consultant billing
review procedures to ensure
that unallowable costs are not
claimed
What Action Was Taken
The audit report was issued to
the Regional Administrator,
Region 9, on September 2,
1986 A response to the audit
report is due December 1,
1986
-------
Ineligible Change
Order and
Excessive
Inspection Fees
Increase Claim by
Almost $880,000
Hitchcock, Texas audit profile
Problem
The City of Hitchcock, Texas,
claimed $691,607 from a
change order for construction
costs not eligible for Federal
participation. In addition, the
City claimed $188,202 in
excessive inspection costs.
We Found That
EPA awarded the City of
Hitchcock, Texas, a $6,102,328
grant for a wastewater
treatment facility and
rehabilitation of sewer lines A
$691,607 claim based on
changed work site conditions
was submitted by the
construction contractor to the
City The claim disputed by the
City was submitted for binding
arbitration and the contractor
prevailed The City then
submitted a change order to
EPA to cover the arbitration
award
The Texas Department of
Water Resources (TDWR) and
EPA examined the change order
and found it ineligible for
participation by EPA Therefore,
we questioned $691,607 as
ineligible construction costs
Additional claims of $188,202
for project inspection services
were set aside for review by
EPA The original contract for
inspection services was
amended by the City and TDWR
to cover a 52 percent increase
in inspection costs without any
apparent change in scope of
work
We Recommended That
The Regional Administrator,
Region 6
• Recover the Federal share of
questioned costs, and
• Evaluate the set-aside costs
for reasonableness
What Action Was Taken
The audit report was issued to
the Assistant Regional
Administrator for Management,
Region 6, on May 2, 1986 The
Region's final determination
letter of August 26, 1986,
sustained $217,144, the Federal
share of costs questioned
Grantee Claims
Over $840,000 of
Ineligible Costs
Delta Diablo, CA audit profile
Problem
The Delta Diablo Sanitation
District, California, claimed
almost $850,000 of ineligible
engineering and
administrative costs. An
additional $283,500 in
landscaping and legal costs
have been set aside pending
review of eligibility.
We Found That
EPA awarded the Delta Diablo
Sanitation District, Antioch,
California, a grant to construct
wastewater treatment facilities
The grantee claimed costs
totalling $847,900 which were
not allowed by EPA regulations
These costs included
• $579,277 incurred after the
authorized completion date
because of a contractor's lack of
performance,
• $108,761 of
architectural/engineering fees
based on inapplicable
construction costs,
• $120,400 of administrative
costs outside of the approved
project scope,
• $26,200 of excess legal
defense claims, and
• $12,343 in revenue from the
sale of plans and specifications
We also set aside $283,500
claimed by the grantee for
potentially excessive
landscaping work and legal
defense costs incurred without
prior EPA approval
We Recommended That
The Regional Administrator
• Not participate in the Federal
share of questioned costs
($651,200), and
• Determine whether EPA
should participate in the Federal
share of set-aside costs
($217,700)
What Action Was Taken
The audit report was issued to
the Regional Administrator,
Region 9, on June 26, 1986 As
of October 21, 1986, we had
not received a response to the
report which was due
September 26, 1986
Grantee Claims
$776,500 of
Ineligible and
Unsupported Costs
Ann Arundel County, MD audit profile
Problem
Anne Arundel County,
Maryland, claimed ineligible
costs of $611,500 which did
not comply with EPA
regulations, including over
$252,000 previously
disallowed.
We Found That
The county was awarded an
EPA grant for the design and
construction of a wastewater
treatment plant The ineligible
costs consisted primarily of
• $267,100 of project
inspection fees incurred after
the approved construction
completion date,
• $252,000 of construction
change order costs previously
determined ineligible for Federal
participation,
• $33,400 of engineering cos
for services performed under
contract amendments deemec
ineligible by the State of
Maryland, and
• $29,800 of training costs fo
the operation of ineligible
construction items and
therefore not allocable to the
EPA funded portion of the
project
In addition, the grantee
received a settlement for
engineering services under a
civil action and was unable to
document whether these
related costs were also caime
for Federal participation We
therefore referred additional
costs totalling $165,000 to EP,
for review
We Recommended That
The Regional Administrator,
Region 3
• Recover the Federal share c
questioned costs ($336,319),
and
• Determine whether EPA
should participate in the costs
referred for review
What Action Was Taken
The audit report was issued tc
the Admin/strator, Reg/on 3, o,
April 9, 1986 A proposed final
determination on the costs
claimed was due on July 7,
1986 However, as of October
24, 1986, we had not yet
received that final
determination
14
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Grantee Claimed
Over $1 Million of
Ineligible,
Unsupported, and
Contract Overrun
Costs
MSO Chicago, IL audit profile
Problem
The Metropolitan Sanitary
District of Greater Chicago,
Illinois, (MSD) claimed
$733,800 of ineligible costs
were outside the scope of the
grant or undocumented. An
additional $295,000 of cost
overruns were set aside.
We Found That
EPA awarded a grant to the
Metropolitan Sanitary District of
Greater Chicago for construction
of intercepting sewers serving
the proposed O'Hare Water
Reclamation Plant Of the $62 8
million audited, we questioned
$733,800 of claimed costs that
were for construction outside
the scope of the grant or were
unsupported and
undocumented Similar
deficiencies in MSD grant
claims were reported in
previous semiannual reports
Specifically, we questioned
$394,100 for the enlargement of
a drop shaft with increased fiow
capacity in a segment of the
system excluded from grant
support We also questioned
$220,200 of construction costs
related to an unsupported
settlement of a law suit, and
$119,500 of force account costs
incurred after the approved
construction completion
In addition, $295,000 of
claimed construction costs were
set aside pending review and
approval by EPA concerning
primarily large overruns for rock
bolting and water inflow
grouting which may have been
used to accommodate the
contractor's construction
procedures, and may not benefit
the structural integrity of the
permanent structure
We Recommended That
The Regional Administrator,
Region 5
• Not participate in the Federal
share of questioned costs
($550,300), and
• Determine whether EPA
should participate in the Federal
share of costs set aside
($221,300)
What Action Was Taken
The audit report was issued to
the Regional Administrator,
Reg/on 5, on August 7, 1986 A
response is due November 5,
1986
Grantee Claims
Over $650,000 of
Unsupported Costs
on Oversized
Project
Uxbridge, MA audit profile
Problem
The Town of Uxbridge,
Massachusetts, claimed
$516,658 of undocumented
questioned costs and an
additional $135,000 of
unapproved change orders
and miscalculated fees that
were set aside.
We Found That
The grantee was awarded a
construction grant for a
secondary wastewater
treatment plant, interceptors,
force mams, pumping stations,
and collector sewers The
project may have been
oversized since at the time of
final inspection its average flow
rate was only about one-tenth
of capacity
The grantee claimed over
$435,000 of ineligible costs
based upon unapproved change
orders and over $80,000 of
administrative, architectural, and
engineering fees that were not
within the scope of the project
In addition, $135,000 for
construction, architectural,
engineering, and inspection
costs and fees, and excess
profits were set aside pending
justification
We Recommended That
The Deputy Regional
Administrator, Region 1
• Not participate in the Federal
share of questioned costs
($387,494),
• Determine whether EPA
should participate in the Federal
share of costs set aside
($101,240), and
• Recover the applicable
amount due from the grantee
after complying with the above
recommendations
What Action Was Taken
The audit report was issued to
the Deputy Regional
Administrator, Region 1, on
June 12, 1986 The final
determination from the Deputy
Regional Administrator
sustained $426,071 (Federal
share) of costs questioned and
set aside
City of New York
Claims Over
$640,000 of Costs
Previously
Disallowed
City of New York audit profile
Problem
The City of New York claimed
costs totalling $641,470 for a
construction contract declared
ineligible by the New York
State Department of
Environmental Conservation
(NYSDEC). In addition,
$641,662 was set aside
pending evaluation by the
Regional Administrator,
Region 2.
We Found That
Two grants with maximum
Federal participation of
$144,047,754 were awarded in
September 1979 to the City of
New York for the purchase of
equipment and construction of
facilities as part of the City's
sludge management plan May
1982 amendments terminated
the grants and decreased
Federal participation to
$16,286,495
The $641,470 of disallowed
costs represents the entire
amount claimed under one
particular contract between the
City of New York and one of its
contractors The NYSDEC
(acting in a delegated capacity
for EPA) ruled the contract
ineligible because the services
provided were for engineering
design, which was not within
the scope of the project In
addition, costs included under
this contract for equipment and
supplies were incurred before
the grant award and therefore
were outside the scope of the
project We agreed with
NYSDEC's determination and
questioned the ineligible
contract costs
Set-aside costs of $641,662
consisted of construction costs
possibly duplicated and
engineering and inspection fees
either outside the scope of the
project or lacking supporting
documentation
We Recommended That
The Regional Administrator,
Region 2, not provide Federal
funding for $481,103 (Federal
share) of unallowable costs
Further, we recommended that
the action official evaluate the
appropriateness of funding
$481,247 (Federal share) of
set-aside costs
What Action Was Taken
The audit report was issued to
the Regional Administrator,
Region 2, on June 23, 1986 As
of October 23, 1986, we had
not received a response to the
report which was due
September 23, 1986
15
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Superfund
Program
The Superfund program was
created by the Comprehensive
Environmental Response,
Compensation, and Liability Act
of 1980 (CERCLA) The Act
provides a $1 6 billion trust fund
for removal and remedial
actions, liability, compensation,
cleanup, and emergency
response for hazardous
substances released into the
environment and uncontrolled
and abandoned waste sites
Taxing authority for the trust
fund expired on September 30,
1985 At the end of this
reporting period Congress was
still considering a reauthorization
bill This bill, the Superfund
Amendments and
Reauthorization Act of 1986,
was enacted on October 17,
1986 It provides $8 5 billion to
continue the program for the
next 5 years, makes numerous
programmatic revisions, and
imposes some manda- tory
auditing and reporting
requirements on the IG
The parties responsible for
the hazardous substances are
liable for cleaning up the site
themselves or reimbursing the
Government for doing so
States in which there is a
release of hazardous materials
may qualify for assistance from
the Superfund by agreeing to
pay 10 percent of the costs of
remedial actions, or 50 percent
if the source of the hazard was
owned and operated by the
State or local government
Costs claimed by the State from
Superfund must be clearly
eligible and supported
EPA Pays
Excessive Amounts
for Emergency
Cleanups of
Hazardous Wastes
Problem
The urgent need for
emergency hazardous waste
cleanups led EPA to award
multimillion dollar contracts
for Emergency Response
Cleanup Services (ERCS) with
limited competition and
without assurances that the
negotiated rates were
reasonable. As a result, EPA is
paying excessive amounts for
the emergency cleanups.
Background
Following Superfund
authorization in 1980, EPA
initially used Notice to Proceed
contracts authorizing a specific
firm to perform emergency
cleanups However, the rates
and other terms of the contract
were frequently not finalized
until the cleanup was well
underway or completed The
ERCS contracts were meant to
provide a better approach for
obtaining cleanup services by
dividing the country into four
geographical zones, with an
ERCS contractor responsible for
emergency cleanups in each
zone The zone contracts
specified 126 equipment items
and labor categories for which
fixed rates were negotiated
Other services were
reimbursable under a
cost-plus-fixed-fee arrangement
The potential value of the
contracts over a 3-year period
was $186 million Actual
cleanup work for specific sites
was authorized through
individual delivery orders
We Found That
On the twelve individual delivery
orders audited, ERCS
contractors were paid an
average markup of 40 percent
over their labor costs ard labor
billed to EPA under the fixed
rates ranged from 14 percent to
103 percent over the
contractors' actual costs
Contractors billed labor at
holiday and overtime premium
rates even though they
frequently did not pay these
higher rates to their employee
Contractor and subcontractor
employees who are working
away from home are allowed
per diem expenses to cover
food and lodging. However, w
found that per diem expenses
were invoiced to EPA with an
average 10 percent markup, o
$25,452 more than actual
expenses
Below are some examples <
the overtime rates charged bi
not paid
Category Estimated Costs Overtime
Contract Rates
Chemical Engineer
Clerk
Response Manager
$41 54
$14 14
$35 58
$5880
$21 50
$64 10
Mark
42'
52'
80'
Equipment items were billed
to EPA with markups over cost
ranging from averages of 143
percent on monthly rates to 321
percent on hourly rates
Markups on individual items
varied from 37 percent under
costs on a particular pic
-------
• ERCS Procurement
Discouraged Competition Valid
restrictions and difficult
requirements of the ERCS
contracts discouraged
competition and limited the
number of firms which
submitted proposals Even
though only seven firms
submitted proposals for the four
ERCS contracts (there were
only two proposals in each of
three regions and only one
proposal in one region), the
Agency judged that it had no
real alternative but to proceed
with the procurement
• Reasonableness of Rates
Could Not be Ensured EPA
procurement officials operated
in a poor negotiating
environment during the ERCS
procurement because price
competition, offerer
independence, and price
analysis were all inadequate
Had more complete information
and actual cost data been
available, EPA would have been
able to assess the
reasonableness of proposed
rates by comparing them to
anticipated costs Agency
officials, however, relied
primarily on their knowledge of
prevailing market rates in
determining whether proposed
rates were reasonable Since
we believe market rates for
cleanup services were artifically
high and not based on actual
cost, we do not consider that
this type of analysis could
ensure the reasonableness of
the negotiated rates
• Fixed Rates in the Contract
Permitted Excessive Markups
Procurement officials believed
using fixed rates would simplify
negotiation and administration
of the ERCS contracts This
mechanism, however, allowed
contractors to recover over 100
times their actual costs for
certain items
• Poor Planning Did Not Protect
EPA's Interests EPA
encountered market conditions
where advance contract
planning was critical, yet
difficult The Agency faced a
market where few firms could
do the work envisioned and
knowledge of the resources and
associated costs required to
accomplish emergency cleanups
was limited However, EPA did
not effectively analyze the
information or consider
problems that had arisen on
previous cleanup contracts in
negotiating the ERCS contracts
Ambiguous contractual
provisions led to overcharges in
the areas of overtime and
holiday pay, travel and per diem,
equipment, and management
services
• Transportation and Disposal
Services Were Not Obtained at
Lowest Cost The zone
contractors frequently did not
effectively plan and execute
subcontracts for transportation
and disposal of hazardous
wastes This increased costs to
EPA
• EPA Has Not Conducted
Regular Contract Compliance
Reviews As a result, the
contractors did not always (1)
comply with the terms of the
contract, (2) provide services in
the most cost-effective manner,
or (3) comply with Federal laws
In particular, we found problems
with use of unqualified
personnel, noncompetitive
procurements, and violations of
minimum wage and overtime
pay requirements of Federal
statutes
We Recommended That
• EPA take specific actions to
increase competition on future
emergency removal contracts
by removing barriers which limit
competition and encourage
greater participation of firms in
the industry
• EPA obtain contractor cost
data to evaluate reasonableness
of proposed prices If cost data
are unavailable, the Agency
should use provisional rates
until such data can be
developed.
• EPA limit the use of fixed
rates to services and equipment
directly under the prime
contractor's exclusive control,
and reimburse subcontracted
items on an cost-plus-award-fee
basis
• EPA better plan and execute
future cleanup contracts,
specifically prohibit payment for
unreasonable and unallowable
items, and clarify contract
provisions
• EPA award master contracts
for procurement and oversight
of all transportation and disposa
services and obtain preferred
rates from disposal facilities
• EPA establish a contract
monitoring board to routinely
review contractor compliance
What Action Was Taken
In response to our draft report,
the Director, Procurement and
Contracts Management Division,
agreed with many of our
findings, has initiated improved
contract provisions committed
to increased monitoring, and
established separate rates for
subcontractors These actions
should stop excessive
payments, assure more
competition in contracting and
proper charging and payment of
wage rates The final audit
report was issued September
23, 1986, to the Assistant
Administrator for Administration
and Resources Management
and to the Assistant
Administrator for Solid Waste
and Emergency Response A
response to the report is due on
December 22, 7986
EPA Is Not
Collecting Millions
of Dollars Due
from Polluters
Problem
EPA was not always
aggressively pursuing the
recovery of hazardous waste
cleanup costs. EPA did not
take action to recover
approximately $88.8 million
from responsible parties.
Background
The Comprehensive
Environmental Response,
Compensation, and Liability Act
(CERCLA) of 1980, provides for
the establishment of a $1 6
billion Trust Fund collected from
taxes on petroleum, certain
chemicals, and from Federal
appropriations, to pay for
cleanups of hazardous waste
conditions at sites or spills
CERCLA also provides that
parties responsible for the
hazardous waste conditions
should either perform cleanup
themselves or replenish the
Trust Fund for doing so Once
the responsible party is
identified, EPA must attempt to
negotiate a settlement and
pursue a recovery for the cost
of the cleanup
We Found That
As of September 30, 1985, EPA
had obligated $1 3 billion from
the CERCLA Trust Fund and had
recovered $14 million which is a
cost recovery ratio of 1 1
percent of Trust Fund
obligations Unless EPA
becomes more aggressive in
pursuing cost recovery actions,
its ability to replenish the Trust
Fund and clean up hazardous
waste sites will oe severely
restricted
Recovery action was not
taken in many cases for sites
under $200,000 We identified
182 completed removal actions
under $200,000, totalling more
than $6 mil ion, where EPA was
not pursuing recoveries We
estimate that about $60 million
will be lost to the Trust Fund in
the next 20 years if recoveries
of under $200,000 are not
aggressively sought In addition,
we found another 19 completed
removal cases totalling about
$5 7 million of which recovery is
doubtful
EPA was not taking timely
action to make recoveries We
identified 22 ongoing cleanup
actions costing more than $65
million where potentially
responsible parties filed for
bankruptcy EPA has only
received $27,000 on 2 of the 22
cases Failure to take timely
recovery action jeopardizes
EPA's right as a creditor In
addition, EPA did not have a
monitoring system to determine
if and when a potentially
responsible party declared
bankruptcy
Negotiations between EPA
and potentially responsible
parties were not always
completed within a 60-day
cutoff period Of 411
negotiations, 276 exceeded the
60-day period, with the average
negotiation lasting 279 days
We also found that 31 of
EPA's negotiations with
potentially responsible parties,
totalling almost $7 million,
ended within the Agency's
established timeframes but
were unsuccessful since a
17
-------
settlement was not reached If
a reasonable settlement cannot
be made, negotiations should
be broken off and cost recovery
can be pursued through civil
actions
EPA is at risk of not making
recoveries if a statute of
limitations applies to CERCLA
cases Until this issue is
resolved by Congress in the
CERCLA reauthonzation bill or
by Federal courts, we identified
65 actions, totalling nearly $3
million, which may exceed
applicable statutes of
limitations
EPA does not have a
comprehensive management
information system
consolidating data currently
contained in other Agency
systems to provide better
support for CERCLA recovery
and enforcement actions
We Recommended That
The Assistant Administrator for
Solid Waste and Emergency
Response
• Examine the possibility of
using alternative methods for
pursuing and filing cost recovery
actions,
• Require that minimal cost
recovery actions be pursued for
sites where cleanup costs were
under 5200,000,
• Establish procedures on how
to take the necessary action(s)
to establish EPA's priority claim
in relation to other creditors,
and
• Require that specific steps in
the negotiation and settlement
process are planned, scheduled,
and initiated in a systematic and
orderly manner to minimize
delays in the settlement
process
What Action Was Taken
In response to our draft report,
the Assistant Administrator for
Solid Waste and Emergency
Response agreed to review our
recommendations upon
reauthonzation of Superfund
The final audit report was
issued to the Assistant
Administrator on September 24,
1986 A response to the report
is due December 23, 1986
EPA Program
Offices Need to
Improve
Accounting for
Payroll Charges to
the Superfund
Problem
Several EPA regional and
Headquarters offices were still
not properly accounting for or
documenting payroll charges
to the Superfund
appropriation although this
problem was previously
reported in a 1982 audit of
the Trust Fund.
We Found That
EPA program offices were not
complying with the Agency's
Superfund charging policies for
personnel compensation and
benefits (PC&B) and were not
properly monitoring charges
The ma|onty of the errors noted
could have been prevented
and or corrected had the
problem offices reviewed and
reconciled the payrol
cistnbution records with the
supporting documentation
We could not accept PC&B
obligations of over $6 6 million
for fiscal years 1983 and 1984
without additional information or
evaluations and approvals by
responsible Agency program
officials These findings resulted
primarily from analyses of tne
statistical samples of PC&B
transactions at Regions 1, 3,
and 4, which indicated that the
potential error in the recorded
PC&B costs was not within ,on
acceptable range Therefore,
payroll costs for these Regions
could be misstated by as much
as $739,000
We also found that Superfund
hours recorded in EPA's
financial management system
did not always agree with the
hours recorded on employees'
timecards and or timesheets,
supporting documentation (e g ,
timesheets) was missing or
inadequate, and supervisory
signatures were missing from
documents
As an example, one EPA
program office could not locate
its fiscal 1983 time- sheets to
support its costs As a result,
PC&B costs amounting to over
$1 4 million were set aside
By not charging costs to the
correct appropriation or
maintaining supporting
documentation, EPA could be
violating public law and severely
affecting its ability to recover
costs
We Recommended That
The Regional Administrators and
the Comptroller
• Reemphasize the Superfund
PC&B charging policies, and
• Provide a status report on the
program offices' review of the
PC&B costs, including any
adjustments that were made
What Action Was Taken
These findings are consolidated
from 15 audit reports issued to
various regional and
Headquarters officials during
fiscal 1986
In response to our audits, the
Agency replaced the dual
system of transferring payroll
information from timesheets to
timecards, which resulted in
errors, with a procedure for
distributing payroll costs directly
from the timesheet The Agency
has also begun requiring
centralized filing of timesheets
More Effective
Monitoring Needed
of the New Jersey
Cooperative
Agreements
Problem
Almost $5 million of
unneeded Superfund
cooperative agreement funds
were not deobligated; only 20
percent of remedial
investigations were
completed on time; and
change orders were approved
without assurance of required
analysis.
We Found That
Region 2 did not monitor the
progress or use of funds
associated with the New Jersey
cooperative agreement to
perform remedial cleanup of
hazardous waste sites The
region did not deobhgate over
$4 9 million of unused
cooperative agreement funds
from the Superfund which could
have been made available for
other program priorities
Regional proiect officers are
not actively ensuring that
remedial investigations and
feasibility studies (RI/FS) are
completed within the
established timeframes for the
New Jersey Department of
Environmental Protection
(NJDEP) to award timely
contracts Only 4 of 22 RI/FS
have been completed delaying
the cleanup of the remaining
Superfund sites
In addition, NJDEP did not
submit any quarterly progress
reports of its cooperative
agreements, nor were the
contractor's monthly reports
always forwarded to the regioi
Regional project officers did nc
follow up to ensure that the
required reports were
submitted As a result, technic
progress at the sites could not
be properly monitored
Finally, the region approved
change orders for nine feasibili
studies totalling over $1 1
million without proper
documentation of cost review
On three feasibility studies, thf
change order increases were £
percent, 63 percent, and 54
percent, respectively, of tne
original contract amounts
awarded, although none of
these studies had yet been
completed The NJDEP is no:
documenting required analyses
for change orders and regional
staff are not adequately
monitoring the State's review <
change orders
We Recommended That
The Regional Administrator,
Region 2, direct
• A review of Superfund
cooperative agreements and
State reports to determine if
there are additional funds that
could be deobligated,
• Project officers to become
more actively involved in
ensuring that current NJDEP
RI/FS are completed within
required timeframes,
• New Jersey Remedial Actior
Branch to require NJDEP to
submit all required quarterly
progress reports, and
• The New Jersey Remedial
Action Branch to ensure tiat
the required cost analyses are
performed by NJDEP for all
change orders over $10,000
What Action Was Taken
The audit report was issued to
the Regional Administrator,
Region 2, on September 25,
1986 A response to the repor,
is due by December 24, 1986
18
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Section 2—Audit Resolution
As required by the Inspector
General Act, this section
describes significant problems
identified in previous
semiannual reports which
remain unresolved. Also, as
required by the Supplemental
Appropriations and Rescission
Acts of 1980 and 1981, this
section includes a summary
of unresolved audits and a list
of officials responsible for
resolving audit findings over 6
months old.
Overdue Audit
Resolutions Hit All
Time Low
As a result of priority placed on
the audit resolution process by
EPA management and the
Office of Inspector General, the
level of overdue audits hit an all
time low during the past 6
months Overdue items as of
September 30, 1986, totalled
18, down 14 percent from the
21 reported at the end of the
first half of 1986 During the
second half of 1986, 773 audits
were closed and 788 new
audits were issued, leaving 369
audits in the system for
resolution during the next 6
months
On the closed audits, $31 7
million of questioned costs
were sustained The sustained
costs included $27 5 million for
cost recovery and $4 2 million
of cost reductions In addition,
recoveries in current and prior
periods included $3 8 million in
cash collections and at least
$127 million in offsets against
billings
EPA management continues
to emphasize both timeliness
and quality of audit resolution
Four special task force projects
from last year's National Audit
Resolution'Assistance Disputes
Conference have been
completed The task forces
recommended specific actions
to further improve the quality of
the Agency's audit resolution
functions Steps are underway
to implemen: these
recommendations
• The Office of Comptroller will
prepare and coordinate an
approach for Agencywide
measurements and comparison
of the quality of audit
resolutions Measurement will
be based on operations reviews
and a combination of several
different numerical rating
methods related to appeals filed
and reversals issued
• Agencywide recommended
standard procedures will be
established for the audit
resolution function, and
comprehensive training courses
in the area of audit resolution
will be developed
• A policy announcement will
establish the officials
responsible for coordinating and
resolving findings contained in
Superfund audit reports This
action will provide common
points of contact throughout the
Agency and will ensure timely
resolution of Superfund audit
issues
• Chapter 35 of the Assistance
Administration Manual will be
revised to include guidance on
the use of Revised Final
Determination Letters under
certain circumstances
• Management will prepare a
Notice of Proposed Rulemaking
which will amend 40 CFR Part
30, General Assistance
Regulations, to limit the
timeframe for auditees to
submit supporting
documentation to refute
disallowed costs
• Management directors will
review and modify, as
appropriate, State delegation
agreements to improve State
involvement in the audit
resolution processes, including
draft audit report reviews and
issues related to
documentation
A Special Review
Disclosed
$75.8 Million in Reporting
Errors Distort Agency
Accomplishments
Problem
Reported Agency recoveries
on audits are substantially
less than amounts the Agency
agreed to recover. Close
analysis of the differences is
prevented because the
Agency's tracking reports are
substantially incorrect. Actual
recoveries appear to be
substantially higher than
reported recoveries.
We Found That
Controls in the Financial
Management D'Vision over
accounts receivable and
collection efforts were not
effective Receivables totalling
$3,948,871 were not recorded
on the general ledger For
recorded items, collection actior
on 5693,266 was not taken
when it should have been
Other errors regarding
receivables and collections
included wrong coding on the
active inactive status of
receivables, minus amounts
appearing as collections, and
negative receivable balances
The Financial Management
Division is also responsible for
tracking and reporting on the
disposition of costs sustained
for recoveiy on audits Their
audit tracking reports contained
numerous inaccuracies because
the function was considered a
low priority and no current
instructions were available to
guide completion of the leport
Examples of errors include
• $75 8 of $186 8 million of
sustained costs were not
tracked on the reports even
though they should have been
Therefore, many millions of
dollars of audit benefits were
not identified as Agency
accomplishments
• Items were reported as
recoveries by offset when, in
fact, they were amounts
conceded on appea
-------
Previously
Reported
Items—Corrective
Actions Not Taken
The Inspector Genera! Act
requires that each semiannual
report identify unresolved audits
discussed in previous reports
One hundred and four audit
reports were discussed in all
previous reports, 103 have been
resolved The audit report listed
below has not been resolved as
of September 30, 1986
Reporting system errors have
resulted in reports being
provided to the Administrator
and Congress that contain large
inaccuracies and that appear to
substantially understate the
benefits derived from audits
Because of the severity of the
reporting problems, it was not
possible to closely analyze the
reasons for the large differences
between reported recoveries
and sustained costs
We Recommended That
The Comptroller provide
instructions emphasizing the
importance of accurate
reporting Further, the Financial
Management Division
assessment reviews should
periodically evaluate these
activities Finally, the Agency
should implement improved
procedures for controlling
receivables and collections
What Action Was Taken
The responsible offices agreed
to take appropriate corrective
action during our review Action
has already been taken for
many of the issues reported
For example, instructions for
completing the audit tracking
report were completed The
Comptroller will provide our
office with a report on
corrective actions taken by
December 31, 1986
Action Officials for Audit Reports Outstanding
More Than Six Months as of September 30, 1986
Audit Grantee/Contractor
Number
Issue Date
Stati
/
/<•
Action Official ^3-
EPA Grants Programs
Director, Grants 2
Administration Division
Regional Administrator, 1
Region 2
Regional Administrator, 10
Region 3
Regional Administrator, 1
Region 4
Regional Administrator, 4
Region 9
1 1 — —
— 1 — —
— 8 1 1
— 1 — —
3 1 — —
Total 18 4 12 1 1
"Incomplete audit responses open 90 days or more past report date will be
handled as a nonresponse in accordance with EPA Directive 2750
Management of EPA Audit Reports and Follow-up Actions All of the reports
under this category would be considered as nonresponse
60091 Baltimore, Maryland
10/24/85
Incomple
respon;
Resolution of Significant Audits from Prior Periods
Audit Grantee Federal (
Report Share* Susti
Date Questioned for Recc
1/17/86 E2CVV5Q30T7? Philadelphia Water $5,526,865 $1^521
Department
Akron, Ohio
60446
1/31/86 P2dW4050371-
52,765,691 $ 2.76E
$1,160,964 S1.16C
60385
10/30/85 P2cW4030361-
60120
11/14/85 E2cW5070034- Little Blue Valley, MO $2,370,582 $1,059
60623
12/20'85 P2cW4030365
60359
Stafford County, VA 5617,200 S617
V6/86 P2cW4030365- Front Royal, Virginia $596,156
60394
3'2486 P3DG5020174- NJDEP $573,227
60763
12'5;85 P2cW5C)30083-
60307
Mourtaintop Authority, 5549,614
PA
$ 596
S 556
S 549
"Federal share quest oned ncreased up to the amount of costs sustained f>
recovery in those cases where costs sustained for recovery exceeded Fede
share questioned and were the result of action taken on Federal share sei
aside
20
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Section 3—Prosecutive Actions
The following is a summary
of investigative activities
during this reporting period.
These include investigations
of alleged criminal violations
which may result in
prosecution and conviction,
investigations of alleged
violations of Agency
regulations and policies, and
OIG personnel security
investigations. The Office of
Investigations tracks
investigations in the following
categories: preliminary and
regular investigations, joint
investigations with other
agencies, and OIG
background investigations.
Summary of
Investigative
Activity
During this period, we closed
201 investigations At the same
time, we continued emphasizing
long-term, major-impact
initiatives and improving the
quality of investigative work
Pending Investigations 242
as of March 31, 1986
New Investigations 151
Opened This Period
Investigations Closed This 201
Period
Pending Investigations as 192
of September 30, 1986
Prosecutive and
Administrative
Actions
In this period investigative
efforts resulted in 27
indictments and 28 convictions
Fines and recoveries amounted
to$1 9million Atotalof40*
administrative actions were taken
as a result of investigations
*Does not include suspensions and
debarments resulting from Office of
Investigations activities or actions
resulting from reviews of personnel
security investigations
160
Resignations 6
Reprimands/Admonishments 10
Repayment of Funds 10
Removals 4
Suspensions 5
Other 5
The number of prosecutive and
administrative actions resulting
from investigative activity has
continued to increase this
semiannual reporting period and
this fiscal year as displayed
below
Fiscal 1984
Fiscal 1985
Fiscal 1986
Adrnin Actions
FPA Empl
Profile of Pending Active Investigations
By Category of Investigation
Fraud Against the Govt
1 52 79 2%
Other 10 5 2%
Pnv Act Violations 4 2 1 %
Conflict of Interest 9 4 7%
Antitrust 14 7 3%
Personnel Violations 3 1 6%
Profile of Pending Active Investigations
By EPA Office Unit
Research 3 1 6%
Air 33 172%
Administration 17 8 9%
Solid Waste 18 94%
Multiprogram/Other 10 5 2%
External Affairs 3 1 6%
Toxics 6 3 1 %
21
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Description of
Selected
Prosecutive
Actions
Below is a brief description of
some of the prosecutive actions
which occurred during the
reporting period Some of these
actions resulted from
investigations initiated before
April 1, 1986
Bid Rigging: An
Investigative
Priority Yielding
Formidable Results
Since 1983, we have been
investigating trends and
patterns of evidence that EPA
contractors are rigging bids on
wastewater treatment
contracts As of September 30,
1986, 36 indictments, 24
convictions, and numerous
debarments and suspensions
have been obtained for bid
rigging
Town Supervisor
Convicted, Again
Brian Ingber, Supervisor of the
Town of Fallsburg, New York,
and Chairman of the Sullivan
County Board of Supervisors,
was sentenced on September
"9, 1986, to three consecutive
one-year prison terms, fined
$12,000, and held personally
liable for any losses to the W
H 0 Tn-Area Sewer Project
caused by his illegal activity
Wayne Pirnos, coordinator of
the project, was sentenced to
18 months imprisonment,
Service Scaffold, Inc , the
Ingbers' family business, was
fined the maximum $1,000 The
company was also required to
pay restitution to the town if
EPA and the New York State
Department of Environmental
Conservation (NYSDEC) refuse
to reimburse their share of
Service Scaffold's contract EPA
and NYSDEC withheld their
$498,750 payment pending
results of a trial
In a case involving multiple
frauds and violations of Federal
and State laws as described in
our previous semiannual report,
Brian Ingber, his brother
Howard Ingber, Wayne Pirnos,
Thomas Peck (a construction
equipment dealer), and Service
Scaffold, Inc , were charged on
August 23, 1985, with
conspiring to rig bids for an
equipment supply contract on a
$24 million sewer project They
allegedly manipulated the
bidding process by conveying
false information to two
competing bidders so that
Service Scaffold, Inc , would
have a secret advantage in
winning a Government-funded
equipment supply contract The
defendants allegedly concealed
Brian Ingber's conflict of
interest between his business
and position as supervisor of
the town, which included
administering the sewei
projects The defendants were
also charged with rigging
Ingber's 1983 election as
Supervisor of Fallsburg by
forging the signatures of
registered voters on ballots and
fraudulently obtaining signed
absentee ballots
Brian Ingber was convicted on
January 16, 1986, of mail fraud
for forging absentee ballots
during his 1983 election Brian
Ingber and Wayne Pirnos were
found guilty on June 18, 1986,
of making false statements and
Brian Ingber and Service
Scaffold, Inc , were found guilty
of mail fraud
Contractors Fined
and Sentenced for
Rigging Bids on
Philadelphia Water
Project
The Nucero Corporation,
Philadelphia, Pennsylvania, and
its president, Leonard A
Nucero, Sr, pled guilty on
February 13, 1986, to charges
of conspiring with others to rig
bids and fix prices on a
$2,377,000 electrical
construction contract at the
Southwest Water Pollulion
Control Plant in Philadelphia On
May 15, 1986, Mr Nucero was
sentenced to 3 years probation,
fined $50,000 and orde-ed to
perform 400 hours of public
service The Nucero Corporation
was fined $250000
As co-conspirator with Mr
Nucero and the Nucero
Corporation, Wilhard Inc , pled
guilty to rigging bids and fixing
prices on May 8, 1986, and was
fined $125,000
These prosecutive actions
were the result of joint
investigative efforts of the EPA
Office of Inspector General, the
Department of Justice Antitrust
Division, and the FBI
Electrical
Contractor Rigs
Bids on
Chattanoogo
Project
Commonwealth Electric
Company (CEC) and Fischbacr
and Moore, Inc (FMI) were
indicted on July 2, 1986, for
unreasonable restraint of trade
and commerce in violation of
the Sherman Act FMI and CE
were charged with submitting
collusive, artificially high, and
rigged bids for an electrical
construction contract on ihe
EPA-funded Moccasin Bend
Wastewater Treatment P ant
project in Chattanooga,
Tennessee
The indictment further
charged that CEC and FMI
agreed that CEC would be the
low bidder and, in return for
FMI's participation in the
conspiracy, CEC would make
monetary payoff to FMI out ol
the profits CEC expected to
earn from the contract or CEC
would submit a collusive,
artificially high, and rigged bid
for FMI on a future project
FMI was convicted and CEC
pled nolo contendere FMI wa
fined $500,000 and CEC was
fined $400,000 on September
29, 1986 EPA is seeking civil
recoveries from both FMI and
CEC While FMI has been
debarred from doing business
with EPA, CEC has been
suspended
The indictment and
convictions resulted from the
joint efforts of the Deparlmen
of Justice Antitrust Division ar
the EPA Office of Inspector
General
Five Indictments
Short Circuit
Electrical
Contractor's Bid
Rigging Scheme
Dynalectnc Company, McLeai
Virginia, Fischbach and Moore
Inc , Dallas, Texas, Paxson
Electric Company, Jacksonvilf
Florida, G W Walther Ewatt,
President of Dynalectnc
Company and Wesley C
22
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Paxson, Sr, President of Paxson
Electric Company were all
indicted on September 19,
1986, for mail fraud and
unreasonable restraint of trade
and commerce in violation of
the Sherman Act
The defendants were charged
with conspiring to rig bids and
fix prices on an electrical
construction subcontract on the
EPA-funded Snapfmger Creek
Waste Water Treatment Project,
DeKalb County, Georgia
The indictment charged the
defendants with submitting
collusive, noncompetitive bids
so that Paxson Electric would
be the low bidder and receive
the electrical construction
subcontract at the artificially
high sum of $4,915,000
In return for Fischbach and
Moore's participation in the
scheme, Paxson Electric
allegedly agreed to forgive Ms
preexisting debt of $89,330 06
In return for Dynalectnc's
participation, Paxson Electric
allegedly agreed to form a silent
joint venture with Dynalectnc
pursuant to which Dynalectnc
would receive 50 percent of the
profits earned from the
performance of the subcontract
and Paxson allegedly then paid
Dynalectnc $880,000 as its
share
These indictments resulted
from the joint efforts of the
Department of Justice Antitrust
Division and the EPA Office of
Inspector General
Project Officials
Embezzle Almost
$65,000 of Grant
Funds
William H Yeary, a Bell County,
Kentucky, official along with
Elmer Cleveland, a former EPA
project officer pled guilty on
July 17, 1986, to charges of
embezzling grant funds and
filing fraudulent travel vouchers
totalling nearly $65,000 Shortly
after being hired by Bell County
to manage a $410,000 EPA
grant, the county official began
systematically converting grant
funds to personal use In
carrying out the scheme, he
terminated the bookkeeper,
developed a close personal
relationship with the EPA
project officer responsible for
monitoring the grant, and used
a facsimile device to forge his
supervisor's signature on
checks, assuming complete
control over all grant funds He
substantially increased his salary
and converted portions of cash
travel advances to personal use
He also used grant funds to pay
for a week-long vacation in
Gatlmburg, Tennessee,
extensive personal phone calls,
and other personal
entertainment
The EPA project officer played
a more passive role in the
scheme and benefitted to a
lesser extent During a 2 1;2
year period, he travelled
extensively with the county
official in connection with the
project To keep the EPA project
officer from blowing the whistle
on the scheme, the county
official used grant funds to pay
for the EPA project officer's
meals, drinks, golf fees, and
occasional motel rooms The
EPA project officer filed
fraudulent travel vouchers for
reimbursement of these same
expenses
The participants attempted to
cover up the scheme by
discouraging audits and
destroying or altering records
However, based on the strength
of allegations, an OIG auditor
worked effectively with the FBI
and independent third parties
such as banks, credit card
companies, and telephone
companies to reconstruct
enough records to prove fraud
Mr Yeary and Mr Cleveland
were each sentenced to 3 years
imprisonment on September 25,
1986 All but 60 days of Mr
Cleveland's sentence was
suspended However, he was
also fined $1,000 and ordered to
perform community service
while on probation
This case, developed by the
Office of Audit in response to a
direct request by the FBI, is
particularly important to EPA
since it will be given
widespread publicity to deter
future schemes
Construction
Company
Managers Indicted
for Fraud on Sewer
Project
William B Kruse, Project
Manager/Superintendent,
William F Jordan, Project
Foreman, and Charles B Bryon,
Project Foreman, all of Gates
and Fox, Ltd , construction
company, were indicted on
June 27, 1986 The indictments
were for false claims, false
statements, and mail fraud in
connection with a $1 4 million
EPA-funded contract with Gates
and Fox, Ltd , for 19,000 feet of
sewer pipeline in the City of
Corning, California
The contract specifications
required that the pipeline be
surrounded with rock over the
entire length of the project This
rock "envelope" was needed to
provide support to the sewer
conduit and to prevent cracking
and collapse of the pipeline The
ndictment charges that as part
of their scheme to defraud, the
defendants ordered that pipeline
be covered with native soil
rather than with the layer of
rock called for in the contract,
that the defendants allegedly
regularly employed "spotters"
at the job site who were
instructed to alert the pipeline
construction crew whenever the
contract inspector approached
the area wnere native soil was
fraudulently used, and that the
defendants ordered that a layer
of rock be placed over
designated sections of the
pipeline that might be subject to
observation, thereby making it
appear as if the entire pipeline
had been properly back-filled
The false claim, false statement,
and mail fraud violations
allegedly occurred as the
defendants falsely stated and
claimed that the project was
completed according to
specifications and used the
mails to fraudulently obtain
payment The deficient
construction which could have
caused the failure of the
pipeline was subsequently
corrected by the construction
company at a cost of $300,000
On August 26, 1986, Bryon pled
guilty to making false
statements
Illegal Gray Market
Cars
Since our last semiannual
report, we continued working
jointly with Federal and State
agencies investigating "gray
market" auto dealers who
illegally sell imported cars that
have been falsely certified to
meet Federal standards Gray
market auto dealers import cars
to the United States, modify
them to meet U S safety and
EPA emission standards, and
resell them for far less than
U S franchised dealers The
problem concerning EPA is that
many conversions of gray
market cars do not meet
emission standards The OIG is
concerned with modifiers of
gray cars who submit or induce
others to submit false
statements to EPA claiming that
such cars meet these
standards
During this semiannual period
10 persons or firms were
indicted and,or convicted
resulting in $11,200 in fines,
penalties, and corrective
payments, 3 year imprisonment,
8 years probation and over 400
hours of community service An
extradition order has been
issued for one defendant who
has fled the country A similar
scheme investigated 'n different
cases included paying or
inducing 117 individuals to
falsely certify to EPA that they
were each importing a car (Rolls
Royce, Daimler, Porsche,
Mercedes-Benz or Land Rovers)
over 5 years old under a
one time exemption to EPA
emission standards for personal
use rather than resale In all
cases, the cars were in fact
imported for resale
23
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Description of
Selected
Prosecutive and
Administrative
Actions
Concerning EPA
Employees
The OIG investigates and
reports information, allegations,
and indications of possible
wrongdoing or misconduct by
EPA employees and persons or
firms acting in an official
capacity directly with EPA or
through its grantees In addition,
the Senate Report of the
Supplemental Appropriations
and Rescission Act of 7980
states that appropriate
administrative action is
expected to be taken in cases
where employees have acted
improperly
Selected administrative
actions taken against EPA
employees or those with an
official relationship with EPA
during the semiannual reporting
period in connection with audits
and investigations are shown
below
Employee Dials "F"
for Fired
An EPA employee was
terminated from her job on June
4, 1986, based on an
investigation by the OIG during
wnich she admitted making
personal telephone calls on FTS
phones Information indicated
that there were 170 such calls
over a 5-month period with a
value of $361 37 She said the
calls were to a friend
EPA Employee
Suspended for
False Statements
An EPA secretary who
submitted falsified documents
to the EPA Personnel Office
was notified on July 14, 1986,
that she would be suspended
from her job for 21 calendar
days
the suspension resulted from
an OIG investigation during
which the employee admitted
signing her first and second
level supervisors' names on
rating forms she prepared for
herself for upward mobility
positions within the Agency
Former EPA
Purchasing Agent
Prosecuted for
Self-Dealing
Richard Crossgrove, a former
EPA employee, pled guilty to a
criminal information on June 24,
1986, charging him with
performing official Government
acts to affect his personal
financial interest
The information charged that
from May 1982 to September
1985, Mr Crossgrove, while
working as a purchasing agent
for the EPA in Pensacola,
Florida, personally and
substantially participated in
procurement of materials for
EPA from Applied Science
Distributors (ASD), a company
which he founded, operated,
and had a financial interest in
During the investigation, Mr
Crossgrove admitted that he
founded ASD in the name of his
then-14-year old stepdaughter,
who had a different last name,
because "the Government
looked more favorably on
minority-owned business" and
he did not want the Crossgrove
name on ASD's records At first,
Mr Crossgrove collected about
10 percent of the price as profit,
but he eventually increased the
profit margin to about 5C
percent Mr Crossgrove
estimated that ASD's profit
from sales to EPA (its only
customer) totalled about
$12,000 to $15,000
On August 8, 1986, Mr
Crossgrove received a
suspended prison sentence, 5
years probation a $3,000 fine,
and a special monetary
assessment of $50 Mr
Crossgrove resigned from EPA
when he learned that the OIG
would be investigating his
activities
Theft of
Government
Checks Results in
Prosecutive Action
Blair J Lyons, former employe!
Accounting Operations Branch,
Financial Management Division
EPA, pled guilty on Augus: 28,
1986, to the charge of forging
endorsements on U S Treasun
checks
During the investigation,
conducted jointly by the E3A
Office of Inspector General anc
the U S Secret Service, Lyons
admitted stealing 19 checks
worth over $8,000 from the
EPA Financial Management
Division He cashed and forged
at least 14 of them before bein
apprehended
24
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S0Ction 4—Fraud Prevention and Resource Management
This section describes several
activities of the Office of
Inspector General to promote
economy and efficiency and
to prevent and detect fraud,
waste, and abuse in the
administration of EPA
programs and operations.
This section includes
information required by
statute, recommended by
Senate report, or deemed
appropriate by the Inspector
General.
Review of
Proposed
Legislation and
Regulations
Sect/on 4(a)(2) of the Inspector
General Act of 1978 specifies
that it is the duty and
responsibility of the Office of
Inspector General to review
existing and proposed legislation
and regulations relating to
programs and operations
concerning their impact on
economy and efficiency or the
prevention and detection of
fraud and abuse
The total number of items
reviewed by the Office of
Inspector General has increased
approximately 70 percent over
the last semiannual reporting
period We reviewed 70 items
last period compared to 119
items (32 legislative and 87
regulatory) reviewed during this
reporting period The most
significant items reviewed are
summarized below
Reviews of Legislation and Regulations By Semiannual
Reporting Period of Fiscal 1986
P20
•100
'60
-40
20
False Claims Act
The False Claims Act
Amendments have the potential
to be an extremely powerful
tool to the Inspector General
community in fighting fraud The
proposed amendment currently
before the President for
signature would strengthen the
Act However, as we
commented earlier, it fails to
provide testimonial subpoena
authority to the IG community
while providing for a stay of
prosecutive action for claims
filed under the Contract
Disputes Act of 1978 In
addition, the Act may be
amended to protect small
businesses from prosecution
under the False Claims Act
We believe these deficiencies
severely limit the power of the
False Claims Act and the
proposed amendment
DOD Draft
Settlement Bill
We do not agree with the intent
of the DOD Draft Settlement
Bill to increase from $25,000 to
$40,000 the maximum amount
that the U.S. may pay in
settlement of a claim According
to a letter from the Department
of Defense to the Speaker of
the House of Representatives,
few claimants suffer losses in
excess of $25,000 Thus, we
believe there is no
demonstrated need for this
legislation right now
Period Ending 3/31/86
Period Ending 9/30/86
Federal Acquisition
Regulation on
Fraud, Waste, and
Abuse
We reviewed both the Federal
Acquisition Regulation on Fraud,
Waste, and Abuse and the
Department of Defense (DOD)
proposed revisions to the
regulation The proposed DOD
revisions to the Federal
Acquisition Regulation on Fraud,
Waste, and Abuse would be
very valuable in helping to
promote contractor integrity
This provision provides that
the contractor agree to maintain
an employee fraud, waste, and
abuse awareness program, the
purpose of which is to inform
employees of their duties,
rights, and responsibilities for
preventing and reporting fraud,
waste, and abuse Elements
comprising this program are
• Apprising employees of their
responsibilities for preventing
and reporting fraud, waste, and
abuse in an employee
orientation Employees will also
be informed of fines and
penalties for unethical practices,
including conflict of interest,
false claims and statements to
the Government, bribery,
misappropriation of properties
purchased for use on
Government contracts, etc
• Displaying in prominent
locations posters which provide
information on Government
Inspector General Hotline
procedures
• Informing employees of their
responsibilities for ensuring the
accuracy of their time charges
to Government contracts, thus
ensuring the integrity of
contractors' timekeeping
systems
• Discussing with employees
their responsibilities and
liabilities while working on
Government contracts to ensure
a continual awareness of the
contractors' programs for
prevention of fraud, waste, and
abuse
The benefits to EPA of the
proposed revision include
putting contractors on notice
regarding EPA's interest in
preventing fraud It also
establishes a contractual
2E
-------
relationship which provides a
basis for civil actions if
contractors violate their
agreements and facilitates
criminal prosecution of
contractor fraud Based on the
benefits of the proposed
revisions, we strongly
recommend adoption of the
proposal by EPA and all other
Federal agencies
Financial Fraud
Detection and
Disclosure Act of
1986
We reviewed the Financial
Fraud Detection and Disclosure
Act and provided comments to
the Small Business
Administration concerning the
President's Council on Integrity
and Efficiency (PCIE) position on
this legislation Since the
concept of the Inspector
General Act already embodies
many of the principles of this
proposed act, we believe the
PCIE should support this
legislation
Our specific comments on
this legislation relate to the role
of the audit profession in
detecting, deterring, and
reporting fraud We agree that
greater emphasis should be
placed on fraud detection by
auditors certifying the
statements of publicly traded
companies However, we also
believe the auditor should not
be held personally liable for
failure to detect a fraud
concealed by management The
cost of performing an audit so
comprehensive as to make a
personal assurance that no
fraud exists would be
prohibitive As it is now,
auditors are required to show
due professional care when
conducting an audit We further
believe the quality of work by
auditors in the Inspector
General community is well
above the minimum level of due
professional care
We believe the Financial
Fraud Detection and Disclosure
Act, if passed, will have a
positive impact on Offices of
Inspector General in that it will
strengthen the standards of the
entire auditing profession It will
likely result in changes to both
the professional auditing
standards of the American
Institute of Certified Public
Accountants and the
Comptroller General Standards
of Audit of Governmental
Organizations, Programs,
Activities, and Functions
Asbestos
Abatement Draft
Report
We reviewed the Agency
comments on the General
Accounting Office (GAO) Draft
Report, "Asbestos Abatement
GSA's Program Not as Effective
as it Should Be " According to
the GAO report, several Federal
agencies have a role in the
development of asbestos
measurement and abatement
procedures Thus, past efforts
to develop a uniform Federal
approach on asbestos have not
been successful We concur
with the GAO recommendation
that "the Congress should
consider requiring the Office of
Management and Budget to
designate a lead agency to
establish a uniform Federal
policy regarding allowable
asbestos levels in buildings and
uniform techniques to measure
asbestos " We further
recommend that EPA be
designated the lead agency in
this endeavor
Program Fraud
Civil Remedies Act
of 1986
We reviewed the PCIE's letter
to Senator Dole supporting the
Program Fraud Civil Remedies
Act. This Act would enable
Federal agencies to more
aggres- sively and effectively
pursue fraud in Government
programs We believe that
administrative fraud remedies'
would- be a deterrent to those
contemplating fraud against the
Government
We strongly support this
legislation but disagree with the
establishment of the $100,000
junsdictional cap on false claims
that could be adjudicated
administratively under the Act
The $100,000 cap would create
a significant loophole by
restricting agencies from
seeking an administrative
remedy for claims over
$100,000 that the Department
of Justice has declined to
pursue This loophole could
encourage the filing of false
claims that exceed the
$100,000 cap based on the
chance that the Department of
Justice will not pursue and the
agency will have no recourse
If this bill is enacted, we
believe the PCIE should seek to
correct this deficiency,
The
Intergovernmental
Financing Act of
1986
Though the overall purposes of
the Intergovernmental Financing
Act are commendable, we
believe further clarification is
necessary For instance,
language in sedions 4c and 4d
is inconsistent We suggest
substituting language to make
the two sections consistent
with section 2a, which requires
the Secretary to develop
regulations concerning the
transfer of funds
The Act provides for interest
to be paid either to the State or
Federal Government depending
on the time of deposit of the
Federal funds and the time of
payment by the State We
suggest adding language to
provide a reasonable period of
time for transactions to clear
without interest charges to
either the States or the Federal
Government
Section 4k provides for the
reduction of State interest debt
by the amount of additional
administrative cost incurred by a
State in determining the amount
of interest due We believe this
is not feasible since this cost
would be very difficult to
monitor
With these clarifications, we
believe this proposed legislation
will do much to improve the
cash management of Federal
grant programs.
The Existing Clean
Air Act—Criminal
Penalties Needed
Criminal sanctions are not
provided in the Clean Air Act fi
flagrant violations such as
nozzle tampering, fuel switchir
and improper fuel composition
Consequently, current author^
providing for civil penalties ma1
not always result in a
substantive penalty when
considering the violator's
damage to the environment F<
example
An EPA investigation
resulted in a $4 million
proposed penalty agams.t
a distributor for numerous
violations including 540
instances of distributing
leaded gasoline as
unleaded An involuntary
bankruptcy petition
showed the distributor
had no assets, and no
monetary penalty could be
imposed Consequently,
the Office of Mobile
Sources dropped its
proposed penalty and no
further action against the
violator was taken
EPA sent to the Office
of Management and
Budget a proposed bill
"The Improved
Environment Enforcement
Act of 1985." The bill
would improve EPA's
ability to enforce
compliance with
environmental legislation
across its multi-media
regulatory programs fairly
and effectively As further
support for the need for
criminal penalties, we
suggested that Agency
officials present examples
of violations where
criminal or mjunctive
actions would be
appropriate.
26
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Suspension and
Debarment
Activities
EPA's policy is to do business
only with contractors and
grantees who are honest and
responsible, and who comply
with applicable rules and
regulations EPA enforces this
policy by suspending or
debarring any organization or
person who has acted
improperly, has a history of
substandard work, or has
willfully failed to perform on
contracts funded by EPA (or in
some cases contracts that are
funded by other Federal
agencies) The convicted felon
is by far the most frequent
subject of an EPA debarment
Suspensions, debarments, and
voluntary exclusions deny
participation in Agency
programs and activities to those
who represent a risk of abuse
to the Government Such
actions aid in preventing our tax
dollars from being given to
dishonest or nonresponsible
contractors and grantees
The EPA Grants
Administration Division operates
the suspension and debarment
program in EPA Acting by
Agency request or by its own
authority, the OIG conducts
audits, investigations, and
engineering studies, obtains
documents, and provides
information and evidence used
in determining whether there is
a cause for suspension or
debarment
Summary of
Suspension and
Debarment
Activities
EPA is aggressively seeking
debarment and suspension of
dishonest and nonresponsible
contractors EPA has taken
action against more contractors
this fiscal year than in any other
previous year
Suspension and Debarment Activity By Fiscal Year
r140
sjspensionb
settlements
Fiscal 1984
Fiscal 1985
Fiscal 1986
debarments
Summary of Suspension and
Debarment Activities
April 1, 1986 to Fiscal
September 30, 1986 Year
1986
Cases Opened 203 379
Cases Completed
Debarments 40 77
Voluntary Exclusions 2 13
Settlements 10 12
Closed after investigation 24 46
Total 76 148
Active Cases As of 9/30/86
Under Investigation 141
Under Program or Counsel Review 244
Proposed for Debarment 10
Suspended or Suspended and 22
Proposed for Debarment
Other Pending 13
Total 430
Actions to Debar
and Suspend
Persons and Firms
• Charles Beckham, former
Director of the Detroit Water
and Sewerage Department, was
debarred for 3 years on July 31,
1986 following his conviction for
RICO violations (Racketeer
Influenced and Corrupt
Organizations), Hobbs Act, mail
fraud, and aiding and abetting
The violations were in
connection with the award of a
waste removal contract by the
City of Detroit Four other
persons and one firm also were
debarred in this case
- Darralyn Bowers, principal
owner of Vista Disposal, Inc , of
Detroit, Michigan, was debarred
for 3 years following her
conviction for RICO violations,
mail fraud, and aiding and
abetting In February 1986, Vista
Disposal was forfeited to the
Government pursuant to
applicable provisions of the
RICO statute but not debarred,
since debarment would have
diminished the value of the
Government's asset
- Wolverine Disposal, Inc , of
Ypsilanti, Michigan, Joseph
Valenti, and Sam Cusenza,
president and vice president,
respectively, were debarred for
3 years on April 3, 1986,
following the conviction of Mr
Valenti and Mr Cusenza for
RICO violations
- Charles Carson, attorney for
Vista Disposal, Inc , was
debarred for 3 years on April 26,
1986, following his conviction
for mispnsion of a felony The
court also suspended Mr
Carson from the practice of law
- As reported in our semiannual
report for the period ending
March 31, 1986, Jerry B
Owens was debarred for 3
years on March 27, 1986, for
his part in these activities
27
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• Pipeline Renovation Services,
Inc (PRS) of Tacoma,
Washington, was debarred for 3
years on August 8, 1986, along
with owners Constantino and
Dolores Sarandos, husband and
wife, and Constantino's brother,
employee George Sarandos
The debarments followed the
Brownsville, Texas, Public
Utilities Board's termination of
PRS' services under their
contract since PRS had failed to
complete the work within the
time allowed, performed
substandard work, failed to pay
subcontractors, laborers and
matenalmen, and submitted pay
requests and received payment
for work not performed on an
EPA-funded contract The Public
Utilities Board filed suit against
PRS on December 27, 1985,
and was granted a default
judgment in the amount of
$1,272,286 Constantino and
Dolores Sarandos have filed a
petition for reorganization under
Chapter 11 of the U S
Bankruptcy Code
• Lizza Industries of Roslyn,
New York, and its vice
president, Herbert Hochreiter,
were debarred for 3 years on
September 11, 1986, based on
Lizza's conviction for mail fraud
and racketeering and on Mr
Hochreiter's conviction for mail
fraud, racketeering, and perjury
The charges related to work on
highway construction projects in
the State of New York. Also
debarred for 3 years on
September 11,1986, were Azzil
Trucking Co , Inc , and
Midhampton Asphalt
Corporation, both of Roslyn,
New York, which are wholly
owned subsidiaries of Lizza
Industries, Inc
• American Recovery Company,
Inc , of Baltimore, Maryland, and
two of its employees were
debarred for 3 years The
corporation and the employees
had been convicted of receiving
hazardous substances and
dumping them into Chesapeake
Bay This case is part of a new
EPA initiative to debar firms
whose environmental crimes
demonstrate that they are not
responsible enough to perform
on government projects
Bid Rigging-
Prosecution
Results in
Debarments
• Fischbach and Moore, Inc
(FMI), of Dallas, Texas, and two
of its subsidiaries were
debarred for 18 months on April
28, 1986 Fischbach is the
nation's largest electrical
construction contractor and a
frequent participant in
EPA-funded projects FMI and
its affiliates have been
convicted of bid rigging four
times and indicted nine times
One of those convictions was
on an EPA-funded sewer project
in Chattanooga Currently, there
is a pending indictment against
FMI for bid rigging on an
EPA-funded sewer plant project
in the Atlanta area
• Myron R Buggies voluntarily
excluded himself from
participation in the programs
administered by EPA for a
period of 6 months beginning
on July 14, 1986 Mr Ruggles,
who was vice president of Yobe
Electric, Inc , of Sharon,
Pennsylvania, was convicted of
bid rigging on electrical
construction projects in the
Youngstown-Warren, Ohio, area
• Nathaniel Ellis Cannady, Jr,
chairman of the board and chief
executive officer, and G Marvin
Williams, vice president, both of
M B Haynes Electric
Corporation of Asheville, North
Carolina, were debarred for 3
years on July 28, 1986,
following the corporation's
conviction for conspiracy to
obtain property by false
pretenses Mr Cannady and the
corporation were also convicted
for bid rigging on an electrical
contract with the Indian Health
Service Hospital in Asheville,
North Carolina
• J A LaPorte, Inc, of
Arlington, Virginia, was debarred
for 3 years on August 29, 1986,
after being convicted of bid
rigging in connection with a
dredging contract with the U S
Army Corps of Engineers for
maintenance dredging in Upper
Wmyah Bay and Sampit River in
Georgetown, South Carolina
• Gray E Moore, Jr, president
of G E Moore Company, Inc ,
of Greenwood, South Carolina,
was debarred for 3 years on
August 19, 1986, as a part of a
settlement agreement with
EPA, As was reported in our
semiannnual report for the
period ending March 31, 1986,
G E Moore, Inc , was
convicted of bra1 rigging TI
connection with an EPA-funded
construction contract in
Wmnsboro, South Carolina
Minnesota
Project—More Bid
Rigging, More
Debarments
Throughout much of 1985 and
continuing into 1986, the
Attorney General's Office of the
State of Minnesota has been
engaged in a proactive effort to
eliminate bid rigging practices
among the concrete and asphalt
contractors operating in that
State As of September 30,
1986, 73 indictments had been
returned against 24 individuals
and 13 firms While most of the
indictments describe
conspiracies relating to road
construction projects, some of
the contractors also have
contracts with EPA or have
submitted bids on EPA-funded
contracts In each case, EPA
has followed the State
conviction with initiation of a
suspension/debarment action
The following are examples of
debarment cases that have
emanated from the Attorney
General's project in the State of
Minnesota
• Hugo Schulz, Inc , of
Lakefield, Minnesota, and 3 of
its officers were debarred for 3
years on May 1, 1986, following
their conviction for bid rigging
on Minnesota road construction
projects The debarred officers
are Lloyd C Kruse, president,
John A Jerlow, vice president,
and Paul F Smith,
secretary-treasurer
• Rupp Construction Company,
Inc , of Slayton, Minnesota, and
Douglas A Rupp, president of
the corporation, were debarred
for 3 years on July 17, 1986,
following their conviction for bid
rigging on road construction
projects in the District Court for
Nobles County, Minnesota
• Crane Creek Asphalt, Inc , ol
Owatonna, Minnesota, and
Daniel Richard Jerpback, forme
president of the firm, reached
separate settlement agreemen
with EPA on September 4 and
23, 1986 Crane Creek
voluntarily excluded itself from
participation in EPA programs
for 1 year and Mr Jerpback
accepted a 3-year debarment
following his conviction in the
District of Olmstead County,
Minnesota, for perjury during a
investigation of bid rigging on
road construction projects
28
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Employee and
Public
Awareness
A continuing priority of the
Office of Inspector Genera! is to
enhance its presence among
FDA employees grantees, firms
participating in EPA programs
and the public In this process,
we are trying to make those
j'oups aware of their
rt snor'sibility to prevent, detect
ind report instances of fraud
waste, and abuse We have
found that while most EPA
employees, grantees, and
.extractors are conscientious
ioout the economy, efficiency,
and effectiveness of their work:,
they have little knowledge about
me OIG These groups are often
- the tiest position to detect
,/event, and reporf fraud
A'-iste, and abuse 'f they know
nw to identify and report t
To provide information and
encourage participation in
'ulfillmg the objectives of the
QrG, we have useci a variety of
i"ediums to reach specTic
segmonts of the concerned
• vHulahor We have oarticulahv
• ind mat 'ncreas ng aw-arenes--
' >he debarmer' mid
, pension program among
-t ite Attorney General Offices
h i- ten to a dramatic rncrease in
'i • number of dishonest or
1 ' "responsible persons and
' ms being debarred or
- ,->pended from do'ng business
, "i Fp,A In addition,' the
M-'veiopment of publications,
. deotapes, and train,ng in fraud
ejection could prepaie every
pr 'ject or program manager to
id', ntify and report suspected
indicators of fraud thn" may
h.-A<= otherwise gone unnot'ced
Semiannual Report
Over 1,200 copies of our
semiannual report to Congress
frir 'he period ending March 31,
1 'WQ were distributed to
employees citizens news
services, the Army Corps of
Engineers, State agencies
administering EPA programs,
selected environmental
associations, and EPA libraries
We have also expanded our
distribution of semiannual
reports to all members of EPA
concerned committees in both
houses of Congress The
distribution of these reports to
news services 'esulted in the
publication of articles
concerning the OIG and
increased interest by the public
We are particularly interested T
getting State agencies and
grantees more involved in the
prevention and detection of
wasteful or fraudulent activities
The EPA Office of Public AffaTS
has helped us identify
interested audiences and
distribute the semiannual
reports to those groups
Presentations to Management
and Associations
The Inspector General, Deputy
Inspector General, and other
managers in the OIG have
participated in a vigorous
schedule of presentations and
briefings to EPA management in
Headguarters and in the field In
addition, presentations have
been made to grantees,
professional and governmental
associations, State and local
government officials, and
educational institutions For
example several members -if
the OIG have begun
part'cipatrg as m/iruotors n this convention,
we continued developing
cooperative relationships with
numerous State and local law
enforcement agencies to
strengthen our fraud detection
and prevention capabilities
Opportunities lor participation
and presentations are always
welcomed
Articles and Publications
We have been working with
several professional associations
to develop and improve
publications which have a wide
audience in the areas of
environ- mental protection,
auditing, and investigating We
have also continued to develop
and publish articles for EPA
managers and employees by
working with the Office of
Public Affairs and for the public
and specific professional groups
through professional
associations and publishing
services During this semiannual
reporting period, we have
initiated articles in more than
eight different publications
Numerous articles have been
published by newspapers
nationwide concerning the
results of several of our audits
and investigations
Booklet—Indicators of Fraud
in EPA Procurement
The EPA Committee on Jntegrty
and Management Improvement
which is chaired by the
Inspector General issued a 37
page booklet titled "Indicators
of Fraud in EPA Procurement
This publication based on a
similar publication by the
Department of Defense,
describes the nature, potential
for, and types of frauds that can
occur in EPA contracts It
describes specific fraud
schemes and many of the fraud
indicators that can be
recognized, detected, and
reported This document was so
well received that the EPA
Procurement and Contracts
Management D'v.sion has
decided to use it as a part of its
certification course; tor Agency
Project Officers
Awareness
Bulletin—Indicators of Fraud
Also, the EPA Committee; on
Integrity and Management
Improvement issued its fourth
awareness bulletin, titled
"Indicators cf Fraud," m
September 1986 The bulletin,
distributed to all EPA
employees, was designed to
describe some of the most
common types of frauds and
their indicators This awareness
bulletin is a summary of the
more comprehensive booklet
described above
Videotape on Bid Rigging
As a combined effort between
the EPA Office of Water, the
Antitrust Division of the
Department of Justice, and the
Office of Inspector General
participated in the production of
a 30-minute videotape on bid
rigging The videotape, which
features the Inspector General,
the Assistant Inspector General
for Investigations, and the
Associate General Counsel,
Inspector General Division,
along with other program and
antitrust specialists, discusses
what bid rigging is, what its
effects are, how it works, what
laws are violated, and what the
penalties and remedies are Ti->
presentation designed for E -1 '•
program managers, State
agency officials and local
project directors details the
indicators of bid rigging
schemes and how- they car :
recognized and detected T1 -
videotape, complete wth
graphic displays of the major
points, will be duplicated '(•'
ntensive nationwide d^tnbut -
as a potent fraud awamrf^-
tool
Hotline Poster Display
As described in our last
semiannual report and displayed
on the back cover of this repor1
we have had new hotline
posters designed and printed
This semiannual reporting
period, we distributed almov
200 of these posters to F PA
Headquarters and held locaU""-
for prominent display In
addition, we have arranged '.
have the OIG Hotl PC poster
artwork printed on tne nsd
back cover of the EPA
telephone directory tn it •-
distributed to all EPA
Washington D C , area
employees
Development of Fraud
Detection and Awareness
Course
Th'S semiannual period, we
developed a romprenens ve
course entitled "Fraud
Detection and Awareness in
EPA Projects " Tms course w ^
ongmally developed for
presentation to independent
public accoun ants who perform
audits for the OIG on a cont1 i t
basis to increase their
awareness of and ability to
detect and refer indicators o!
fraud to our Office of
Investigations However, trn
course has also been
constructed for presentation tn
a variety of aud'om es
concerned witn the aMity to
detect and prevent fraud in
contracts and projects We have
recently begun receiving and
accepting requests to present
this course to various groups
and organizations
29
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Personnel
Security Program
The personnel security program
is one of the Agency's first-line
defenses against fraud, using
background investigations to
review the integrity of EPA
employees and contractors
During this semiannual reporting
period, the Personnel Security
Staff reviewed 589
investigations identifying the
following conditions and
resulting administrative actions
• Additional inquiry on the
results of an employee
investigation disclosed an
outstanding arrest warrant on a
theft charge The employee
failed to pay a $250 fine and
court costs in 1985 in
connection with that conviction
Local authorities arrested the
employee in 1986 for failing to
meet the conditions of the 1985
bond The employee received a
written reprimand and was
detailed to another position and
office
• Three employees resigned
prior to administrative action
being taken In all three
instances the investigation
developed outstanding arrest
information on the employees
• One employee received a
formal reprimand and was
required to correct the
application for employment after
the investigation disclosed that
the employee was convicted for
driving while intoxicated
• One employee received a
written reprimand and was
required to correct application
papers after the investigation
disclosed that the employee
falsely claimed a college degree
• In 10 other instances not
warranting administrative action,
employees were required to
correct employment applications
on which they had failed to
admit minor arrests and/or
involuntary terminations
We continued working very
closely with Agency program
officials on the implementation
of the 0PM regulations
regarding position sensitivity
designations and granting of
clearances Also during this time
period, the backlog of
adjudications has been
eliminated This will enable the
Personnel Security Staff to
provide more expeditious
service to other EPA offices
Personnel Security Investigations
Adjudicated
President's
Council on
Integrity and
Efficiency
President Reagan established
the President's Council on
Integrity and Efficiency (PCIE)
by Executive Order in March
1981 to attack waste and fraud
and improve management in the
Federal Government The PCIE
coordinates inleragency
activities, addressing common
issues and developing
approaches and techniques to
strengthen the effectiveness of
the entire Inspector General
community Headed by the
Deputy Director, Office of
Management and Budget, the
PCIE includes the 17 statutory
Inspectors General and other
key Federal officials
We participated as members
of the Legislation, Computer,
Coordination, Investigation, and
Law Enforcement Committees,
as well as the Executive
Development and Support
Activities Subcommittee of the
Training Committee The EPA
Office of Inspector General
participated in several PCIE
projects during this semiannual
reporting period The following
describes the activities
coordinated by our office
Support Activities Round
Table
On April 30, 1986, the
Environmental Protection
Agency OIG coordinated the
third "Support Activities Round
Table" sponsored by the
Council's Support Activities
Training Committee The subject
of the discussion—Freedom of
Information Act (FOIA)
requests—provided a forum for
staff members from the
Inspector General community to
examine and discuss the
objectives, problems, and
processes that are involved in
responding to FOIA requests
This round table discussion
included OIG staff members
and managers who are actual
responsible for responding to
FOIA requests In addition,
Gregory Gordon from United
Press International discussed
the FOIA requests he
periodically submits to the
Inspector General Offices Mi
Gordon's presence at the
workshop engendered lively £
spirited exchanges amorg th«
OIG participants
Court-Ordered Restitutions
and Fines
We will provide comments 01
the U S Sentencing
Commission draft guidel nes
be directed at improving
sentencing by impacting the
pre-sentence investigation an
the Victim Impact Statement
that the U S Probation Office
provides to the judge foi
sentencing, and the collectio
efforts of the U S Attorneys'
Offices and the U S Probatic
Office on court ordered fines
and restitution Since the U £
Government is frequently the
victim in these cases, our
efforts should 'improve the
recoveries the Government
makes and benefit the entire
Government
Assessment of Investigate
Planning Standards
This project assesses the ne>
to clarify or expand the
investigative planning standa
which is currently used by th
Inspector General commumt1
and to identify areas of
agreement in setting the
standard Work on this projei
has just started
30
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Hotline Activities
The OIG hotline center received
30 new complaints and
completed and closed 30 cases
during the reporting period Of
the 30 cases closed, 23 were
not valid and did not require
action, while 7 cases resulted in
environmental, prosecutive, or
administrative corrective action
Cases that do not have
immediate validity due to
insufficient information may be
used to identify trends or
patterns of potentially vulnerable
areas for future review The
hotline also received 366
telephone calls where callers
were referred to the appropriate
program office, State agency, or
other Federal agency for
assistance
The following are examples of
corrective action taken as a
result of information provided to
the OIG hotline center
• As the result of a complaint,
$1,065 was recovered from an
EPA employee who used
frequent traveler airline credits
for personal travel to Europe for
himself and his wife
• A complainant alleged that a
Texas company was causing
extensive air pollution and was
not in compliance with EPA air
quality standards As a result of
an investigation by EPA and the
Texas Air Control Board, the
company agreed to implement
control measures that reduced
dust and paniculate emissions
from the plant
Professional
Development:
Organizational
Development via
Human
Resources
Development
During this semiannual period,
the EPA OIG has aggressively
sought to expand opportunities
for organizational development
and more effective utilization of
resources The formation of the
OIG Human Resources Council
marks a high point of these
efforts With members
representing all divisional
offices, all grade levels, and all
functional areas within the
organization, the Council
explores strategies for
enhancing the quality of work
life within the OIG A first
planning meeting was held
September 23-24 at
Headquarters, and key areas of
concern were identified Some
of these included more
orientation to the Agency for
new employees, intensified
team building nstruction on a
divisional basis, expanded job
enrichment and upward mobility
opportunities, improved
recruitment, promotion, and
retention of women and
minorities, and enhancement of
management and employee
communications
Another significant
accomplishment which is aimed
at improving organizational
effectiveness and productivity is
the increased emphasis on
supervisory, management, and
executive training The OIG sent
32 employees to such training
events, including four to the
Congressional Briefing Seminar,
two to the National Training
Laboratory (NTL) Human
Interaction Laboratory, five to
the Department of Army's
Personnel Management for
Executives Program, five to
EPA's Framework for
Supervision, and one to Harvard
University's Program for Senior
Management in Government
Ongoing efforts involving
curriculum development which
were cited in the last
semiannual report and begun in
February are well underway
For this semiannual period,
we approved 202 training
enrollments for a total of 865
days of training Included in
these training and employee
development events were four
auditing courses contracted with
the (nteragency Auditor Training
Program, two professional
development conferences for all
Divisional Inspectors General,
and block enrollments for
courses sponsored by the
Association of Federal
Investigators
This semiannual period we
have actively become providers
of training through course
development and presentation
We have participated as
instructors in the new EPA
Institute that opened in the
Spring of 1986 and have been
invited to expand our
involvement
We have developed two
courses which we will begin
presenting in fiscal 1987 One
course, entitled "Fraud
Prevention and Detection," is
designed to develop and
enhance awareness of the
nature and characteristics of
fraud in EPA contracts and
projects The course will review
the professional standards
concerning the auditors'
responsibility for detecting
fraud, identify types of fraud
and their indicators, and
describe specific audit steps to
detect fraud The course will
also examine successfully
detected and prosecuted fraud
cases and explain how and
when to refer suspected
instances of fraud to the OIG
Office of Investigations
Another course, entitled
"Effective Communications for
Managers," will prepare
managers for effective and
persuasive presentations and
dealing with confrontation
-------
Section 5—Delinquent Debts
The Supplemental
Appropriations and Rescission
Act of 1980 (Public Law
96-304) requires the Inspector
General to report on EPA's
delinquent debts and efforts
to improve the collection of
such debts.
Claims Office
Actions
Claims Office Actions
When servicing finance offices
(SFOs) determine that debts are
uncollectable, they forward the
debts to the EPA claims officer
for disposition The claims
officer may compromise,
terminate, or suspend further
collection efforts en debts under
$20,000 Debts ovei 520,000
must be forwaided ;o the
General Accounting Office or
the Department of ^ustice for
approval of the final resolution
of debts
As of September 30, 19B6
there were 33 accounts
receivable valued at S',653,3" 4
in the claims office For this
reporting period, the claims
officer
• Terminated two debts
totalling $124,016,*
• Collected, in full, a debt
totalling $43,032,
• Compromised on five debts
totalling $561,302 for $488 045,
and
* Returned five debts totalling
$94,747 to the SFO for refe^al
to a private collection agency
Agency Collection Efforts
The Financial Management
Division provided the following
summary of EPA's collection
efforts for the period April 1,
1986, througn September 30,
1986, and accounts receivable
as of September 30 "986
These may not be the Agency's
final figures Although they
reflect the Agency's accounting
records as of September 30,
they are preclosing figures ( e ,
we obtained the figures before
the closing process was
completed)
Collections
Amounts Written off
Interest Assessments
Interest Collections
526,501,516
S 10,997
$ 240,557
$ 119,212
* After an administrative review, one of the debts
($123,184) was determined to bo invalid
Consequently t was withdrawn from tne
Agency's receivables on June 2'i
Accounts Rece.vab e
Nonfedera
Under 90 days old
Over 90 days n d
Total 570,0/9,61 b
Agent y records show that almost 51 percent of
this arrount cons' itu'es receivables which are
being appealed Flcwever, cur study on the
Reasons for the Large Differences Between
Sustained Costs and Recoveries as described at
page 40, shows tnat approximately 70 percent of
this amount is be ng appealed Collection actions
are suspended until the appeals process is
complete
2 This amount ,s 'or debts owed EPA by other
agencies Although these debts dc not have an
impact on the U S Treasur\, they do impact the
Agency's budget Approximately 14 percent of
the total m th'S category is over 90 days old
Staffing Distribution—Fiscal 1986 Ceiling
Office Headquarters Field
Inspector General
Audit
Invest gations
;40
52
Management and Technical
Assessment
Total
23
69
U32
Source
INSPECTOR GENERAL ACT
SENATE REPORT 96-829
Senate Report, Page 11, Resolution of Audits
Senate Report, Page 12, Delinquent Debts
Total
5
I 73
60
23
Section and Pag
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Appendix - Audit Reports Issued
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
01 INTERNAL & MANAGEMENT AUDITS
LETTER OF CRFDIT REG ON I
TOTAL OF REGION 01 !
LETTER OF CREDIT REGION 2
CONSTRUCTION GRANT DELAYED
CLOSURE RFGION 2
TOTAl OF REGiON 0? - 2
EARLY WARNING REVIEW OF
CONSTRUCTION GRANT PROJECT
ST THOMAS, PA
ESD & REG'ONAL. LAB OFFiCFS HA
ADMIN MGMT BRANCH REG'ON .
CHESAPEAKE BAY PROGRAM
TOTAL OF REGION 03 - 4
LETTER 0= CREDIT REGION b
QMS ENFORCEMENT PROGRAM
FOTAi OF REGION Oh - 2
RCRA PERMITS SURVEY REGiON fa
TOTAL OF RFGION 06 - I
AIR PROGRAM 105' REGION 7
TOTAL OF RFGION O/ - I
IMPREST FUND REGION 8
PROPERTY MANAGEMENT REGiON 8
PROCUREMENT MANAGEMENT
RFGION 8
IOTAL OF REGION 08 - 3
COMPLIANCE WITH EPA ETHICS
PROGRAM REGiON 9
VAI UF ENGINEERING ACT'ViTTS
REGION 9
TOTAl OF REijlON 09 - 2
USE OF THE FTS
TOTAl OF HFADOUAPTERS I
02 CONSTRUCTION GRANT AUDITS
E2BW5020024-61402
P2CW5020030-60841
P2CW5020117 60868
f>2CWb0201 70-60900
P2GW5020171 60901
P2CW5020210-60902
P2CWb0201 76-60906
P2CW5020033-60907
P2CW5020016-60925
P2CW5020161 61035
P2CW5020178-61106
P2CW5020179 61107
E2CW5030263-60819
E2CW6030016-60909
E2CW5030248-61089
E2CW5030131-61213
E2CW6030063-61364
P2CW4030200-60820
PRASA PR
PARISH IV' NY
SENECA CO S D NO 1
PRASA
PRASA
PRASA
i KINGSTON TOWNSh'P OF N,
LiVINGSTON TOWNSHIP NJ
PRASA PR
OSWEGO CITY OF NY
SOUTH MONMOUTH REG SE\A
NEW YORK CITV OF NY
08 28 8b
04 1 6 86
NY 04 18 8r>
04 29 8G
04 29 bfa
'-"?, 04 29 86
04 29 86
04 29 86
05 05 86
06 03 86
AUTH NJ 06 23 86
06 23 86
P2CW40201bO-61167
P2CWb020222 61282
P2CW50202>861283
P2CW502022861284
P2CW502017b 61492
P2CW5020155 61500
P2CW50202 14-61 504
P2CW5020185 61505
P2CW5020219 61547
P2CW5020079-61548
P2CW5020064-615bO
P2CW6020103-61 5b2
i-'ASSAIC VALl E> ^FWERAGE COMM
WOODBURY NY
OGDENSBURG C'TY OF NY
FARMINGTON NY
SECAUCUS MUNICIPAL UA NJ
STOCkPORT NY
. TTLL VALLtv VILLAGE OF N
NEW WINDSOR TOWN OF NY
CANAJOHARIE VILLAGE OF NY
CORNWALL NY
POUGHKEEPSiE NY
GRAND ISLAND NY
FREDERICK COUNTY MD
WEST CHESTER-PA
CONFLUENCE BOROUGH PA
ALBRIGHT TOWN-WV
MIDDLETOWN SEWER AUTH PA
ANNE ARUNDFL COUNTY MD
F2CW6040328-60952
E2CW6040013-61b18
E2CW604016b 61b54
P2CW5040225-60815
P2CW50401 24-60899
P2CW2040224-609b1
P2CW5040274-60962
P2CW5040118-60963
P2CW504019461033
P2CW50401 74-61077
P2CW5040203-61078
P2CWb040246-61084
P2BW60401 72-61185
P2CW3040322-61187
P2CW2040244-612b4
P2CW5040259-61322
E2CW5050207-60790
E2BW5050312-60876
E2CW3050216-61309
P2CW4050169-60834
P2CW40501 53-60838
P2DW4050177-60867
P2DW3050422 60958
P2DW4050261-61075
P2CW4050054-61127
P2CW40501 78-61146
P2DW3050438-61154
MACON BiBB CO WSA GA
ENTERPRISE MS
JACKSONVILLE FL
ARCHDALE NC
ESTILL SC
NO CHARLESTON SEWER DIST SC
DECATUR AL
SPARTANBURG SSD SC
TROY AL
HENDERSON NC
VALDESE NC
JEFFERSON CO COMM AL
FLOWOOD MS
WINNSBORO SC
CHESTER S
FRANKFORT MSB KY
DECATUR IL
DETROIT WSD Ml iOH FY 81 83 >
MSD CHICAGO ll
SUSSEX Wl
LANSING Ml
MAHONING CO (YOUNGSTOWNI) OH
TOL EDO OH
DELPHOS OH
BAY CITY Ml
CRYSTAL TWP iSTANTON' Ml
NEORSD C LEVFLAND OH
P2CW60401 16-61446
P2CW5040256-61456
P2CW60401 36-61 51 1
P2CW6040040-61530
P2CW6040205-61531
P2CW5040158-61564
S2CWb040032-60800
S2CW4040298-60808
S2CW4040233-60809
S2CW4040326-60883
S2CW4040324 60953
S2CW4040329-61188
S2CW4040325-61193
S2CW2040337-61b63
S2CW5040151 61565
S2CW1040035-61 566
TOTAL OF REGION 04 - 32
04:01 86
0421 86
08 07 86
04 11.86
04 13,86
04 18.86
05 1486
06 12 86
06 27 86
07 02 86
07 02 86
P2CW4050251 61174
P2CW4050357-61389
P2DW4050264-61390
P2CW4050263 61391
P2CW4050107-61395
P2CW4050350-61503
P2CW4050280-61574
P2DW4050265-61575
S2CW4050356-60795
S2CW4050213-60950
S2CW40b0346-61139
MILTON Fl
^FFFERSON COUNTY COMM A[
VICKSBURG MS
RALEIGH MS
PEARL MS
Cl AYTON CO WATER AUTH GA
NASHVILLE TN
HENDERSONVII LE TN
JASPER TN
SMYRNA TN
SHELBYVILLE TN
BEl LE MEADE TN
PIGEON FORGE TN
CHATTANOOGA TN
CHATTANOOGA TN
CHATTANOOGA TN
OTTAWA CO (GRAND HAVEN) Ml
DETROIT WSD Ml
DETROIT WSD Ml
DETROIT WSD Ml
MWCC ST PAUL MN
MWCC ST PAUL MN
DETROIT WSD Ml
DETROIT WSD Ml
BVRON MN
BUFFALO MN
Wll LMAR MN
IOTAL OF REGION 05 = 22
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issue
E2BW606001 4-60983 INGLESIDE TX 0516/86
E2CW5060096-61097 TRINITY RIVER AUTHORITY TX 0620,86
E2BW6060084-61233 TRINITY RIVFR AUTHORITY TX 07'25,86
E2CW6060074-61371 TRINITY RIVER AUTHORITY TX 08 21 86
P2CW5060023-60921 HITCHCOCK TX 05'02,86
P2CW5060058-60923 FRANKLINGTON LA 05 '02-86
TOTAL OF REGION 06
P2DW5070Q06-60986 GLENWOOD IA 05'19'86
P2CW5070045-61002 WARRENSBURG MC 0522-86
P2CW5070056-61003 OZARK MO 05/22 '86
P2CW5070044-61055 LEBANON MO 060686
TOTAL OF REGION 07
E2CW4080049-60927 GRAND FORKS CITY OF ND 05-05,86
E2CW5080042-61036 GLENDO CITY OF WY 06-03,86
P2CW5080026-60931 DENVER CITY & COUNTY OF CO 05/06 86
P2CW5080001 -60932 ASH CREEK SPECIAL SERVICE UT 05/06 86
TOTAL OF REGION 08
E2CW6090051-61261 HONOLULU CITY & COUNTY OF HI 07'28,86
E2CW6090052-61361 HONOLULU 08/18,86
E6CW6090024-61439 HONOLULU CITY & COUNTY OF HI 09'02,'86
E2CW6090053-61454 HONOLULU CITY & COUNTY OF HI 09/08,86
E2CW50901 35-61 501 HONOLULU CITY & COUNTY OF HI 09/16/86
P2CW509001 5-60878 GERLACH GEN IMPROV DIST NV 04/22/86
S2CW509021 5-60801 NOVATO SD CA 04/03,86
TOTAL OF REGION 09
E2CW51 00074-609 11 WEISER CITY OF ID 04,30'86
E2CW61 00029-60985 YAKIMA CITY OF WA 05/16,86
E2BW61 00037-61 054 KRAMER CHIN & MAYO INC WA 06/06,86
E2CW51 00076-61 164 KODIAK CITY OF AK 07-0886
TOTAL OF REGION
P2CW50601 40-60961 RUSSELLVILLE AR
P2CW50601 30-61 024 BOGALUSA LA
P2CW50601 00-61 063 PASADENA TX
P2CW50601 56-61 064 TULSA OK
P2CW606001 8-61 229 ARTESIA NM
P2CW5060050-61529 SHAWNEE OK
- 12
P2CW6070034-61108 BELLE PLAINE IA
P2CW50701 13-61250 ST CHARLES MO
P2CW6070047-61498 ST CLAIR MO
P2DW5070151-61551 EL DORADO KS
- 8
P2CW5080004-61037 DENVER CITY & COUNTY OF CO
P2CW508001 5-61 038 METRO DENVER SEWAGE DISPOSAL C
P2BW5080069-61192 SHERIDAN CITY OF WY
P2CW5080068-61214 EASTERN FREMONT COUNTY CO
= 8
S2CW50901 1 8-60882 FALLBROOK SAN DIST CA
S2CW509001 2-61 020 SAN FRANCISCO CITY & CO CA
S2CW5090172-61118 DELTA DIABLO SAN DIST CA
S2BW5090157-61270 SAN FRANCISCO CITY & COUNTY CA
S2CW50901 29-61 308 BENICIA CITY OF CA
S2CW50901 85-61 362 EASTERN MWD CA
S2CW50901 84-61 499 SAN MATED CITY OF CA
= 14
E2CW51 00075-61 234 WHITTIER CITY OF AK
P2CW41 00070-61 039 SALEM CITY OF OR
P2CW51 00062-61 066 ANCHORAGE MUNICIPALITY OF AK
10 = 7
05/14/8
05/30/8
06/10,8'
06'10<8'
07 '23/8i
09/24,81
06,24/81
0''/28/8(
09,16/81
09,29/8f
06-03/81
06/03/81
07/16,81
07-22/81
04/23/86
05/29/86
06i/26,86
07/31/86
08/07/86
08/18-86
09,16'8e
07/25/86
06/03/86
06/1 1 '86
TOTAL CONSTRUCTION GRANT AUDITS - 148
03. OTHER GRANT AUDITS
C3EC601 01 14-60791 BERLIN NH 040286
C3EC6010146-60945 BOW NH 05/09/86
C3EC6010147-60946 STRATFORD NH 0509/86
C3EC601 01 48-60947 NEWMARKET NH 05/09/86
C3EC6010161-61085 NEWPORT VT 06/1786
C3EC601 0206-61 176 EXETER NH 07/15,86
D3AG60101 18-60824 EASTERN RESEARCH GROUP INC MA 04,09/86
D3AG601 01 19-60825 CADMUS GROUP INC MA 04,09,86
D3DG6010127-60856 CAMP DRESSER & MCKEE INC MA 04,17,86
D3AG601 01 26-60863 ENTROPHY LIMITED MA 04/1886
D3AG601 01 33-60873 CADMUS GROUP INC MA 041886
D3CG601 01 37-60886 CAMBRIDGE COLLABORATIVE INC MA 04,2486
D3AG601 01 38-60888 QUANTUM ANALYTICS INC Rl 04/25'86
N3GC601 01 15-60796 BANGOR ME 04/02/86
N3GC601 01 17-60797 ANDROSCOGGIN VALLEY COUNCIL ME 04/02,86
TOTAL OF REGION 01
C3EC60201 28-60992 INTERSTATE SANITATION COMM NY 05 20 86
C3EC60201 29-60996 SOUTHEAST NY 05,2086
C3EC6020141-61069 MT PLEASANT NY 06,12,86
C3EC60201 44-61 086 BERGEN CO UTIL AUTH NJ 06/17/86
C3EC6020175-61281 LANCASTER NY 08/06-86
C3EC60201 86-61 374 MANASQUAN RIVER REG SA NJ 08/21/86
C3EC6020190-61419 GLENS FALLS NY 09/08/86
C3EC6020187-61491 SOUTH MONMOUTH REG SA NJ 09,12/86
C3EC6020202-61568 CARMEL TOWN OF NJ 09 30,86
N3GC60201 04-60829 OCEAN COUNTY NJ 04/10,86
TOTAL OF REGION 02 =
C3EG60301 73-60798 CHESTERFIELD COUNTY 04/03/86
C3EG60301 83-60837 ST MARY'S COUNTY MET COMM MD 0411/86
C3EG60301 86-60869 SUSSEX COUNTY-DE 04/18-86
C3EG60301 99-60944 NEW HOLLAND BOROUGH AUTHOR PA 05,08-'86
C3EG6030220-61053 NORTHAMPTON BOROUGH PA 06,0586
C3EG6030225-61100 MANHEIM TOWNSHIP PA 06/20/86
C3EG6030247-61197 VA AIR POLLUTION CONTROL BD-VA 07/17/86
C3EG6030248-61198 BALTIMORE COUNTY-MD 08/02 '86
C3EG6030270-61 249 LAKE WINOLA MUNICIPAL AUTHOR-P 07/28/86
C3EG6030294-61331 ANNE ARUNDEL COUNTY-MD 08/13/86
C3EG6030324-61526 SUSQUEHANNA RIVER BASIN COM-PA 09/23/86
H3CU6030191-60914 VIRGINIA UNIVERSITY VA 05/01/86
H3CU60301 92-6091 5 VIRGINIA COMMONWEALTH UNIV VA 05/01/86
H3CU6030209-61049 TEMPLE UNIVERSITY PA 06/03/86
H3CU6030246-61196 VA POLYTECHNIC INSTITUTE-VA 07/17/86
H3CU6030325-61527 HOWARD UNIVERSITY - DC 09/23/86
N3GG60301 76-60805 ARLINGTON COUNTY VA 04/04-86
TOTAL OF REGION 03 -
C3EG60401 23-60806 WINSTON-SALEM NC 04/07/86
C3FG60401 24-60810 WINSTON-SALEM NC 04/07/86
C3EG60401 45-60884 CHARLOTTE NC 04/23/86
C3FG60401 46-60885 CHARLOTTE NC 04/23/86
C3EG6040147-60891 DOTHAN AL 04/24/86
C3FG60401 48-60892 DOTHAN AL 04/24/86
C3FG60401 98-60990 PENSACOLA FL 05/20/86
C3EG6040142-60997 COBB CO GA 05,21-86
C3EG604021 1-61 104 ROME GA 06/23/86
C3EG6040213-61117 OPELIKA AL 06/2686
C3EG604021 2-61 133 FT LAUDERDALE FL 06/30/86
C3FG6040226-61136 FT LAUDERDALE FL 0630/86
N3GC601 0129-60871 NORWALK CT
N3GC601 013060872 UNIV OF CONNECTICUT CT
N3GC6Q10 149-60948 HARTFORD CT
N3GC6010I81-61057 MASSPORT MA
N3GC601 0189-61 096 CARROLL NH
N3GC601 0190-61 098 CT STATE UNIVERSITY CT
N3GC601 01 91-61 099 FITCHBURG MA
N3GC6010205-61166 VERMONT-ENVIRON CONSERV VT
N3GC6010208-61178 WARWICK Rl
N3GC6010220-61307 NEW BRITAIN CT
N3GC601 0230-61 354 GREATER PORTLAND COUNCIL ME
N3GC6010231-61355 GREATER PORTLAND COUNCIL ME
N3GC601 0242-61 372 BELFAST ME
N3GC601 0255-61 442 NEW HAVEN CT
N3GC601 0256-61 449 EPPING NH
- 30
N3GC6020" 26-60954 ROCHESTER NY
N3GC6020" 42-61070 PASSAIC COUNTY NJ
N3GU6020I73-61286 RESEARCH FOUNDATION - SUNY NY
N3GC6020' 79 61324 MONMOUTH COUNTY NJ
N3GC6020203-61569 AMHERST NY
P3DG50201 09-60804 CHARLES R VELZY ASSOC INC NY
P3BG5020196-60874 CLINTON BOGERT ASSOC NJ
P3DG50201 87-60877 CLINTON BOGERT ASSOC NJ
P3CG502021 2-61 059 NJDEP NJ
=- 19
N3GG60301 78-6081 7 VA DEPT OF HEALTH-VA
N3GG60301 77-6081 8 CENTRAL VA PLANNING COMM-VA
N3GG60301 80-60826 VIRGINIA BEACH CITY VA
N3GG60301 81 -60830 METRO WASHINGTON GOVERNMENTS
N3GG60301 85-60857 MONTGOMERY COUNTY VA
N3GG60301 84-60859 ALEXANDRIA CITY OF
N3GG60301 89-60870 MARYLAND STATE MD
N3GG6030201-60956 ROANOKE COUNTY VA
N3GG6030202-60957 ROANOKE CITY VA
N3GG6030243-61184 DELAWARE STATE-DE
N3GG6030244-61194 PORTSMOUTH CITY-VA
N3GG6030245-61195 BOWIE CITY-MD
N3GG6030269-61248 DELAWARE VALLAY REG PLANN COM
N3GG6030317-61514 PULASKI TOWN OF - VA
N3GG6030320-61521 HOWARD COUNTY - MD
N3GG6030334-61537 BALTIMORE CITY-MD
P3DG5030241-61004 AARP
= 34
C3EG6040252-61246 ALA DEPT ENVIRONM MGMT AL
C3FG6040258-61247 ALA DEPT ENVIRON MGMT AL
C3EG6040255-61255 SC LAND RESOURCE CONSER COMM
C3EG6040248-61314 JACKSONVILLE FL
C3FG6040249-61315 JACKSONVILLE FL
C3EG6040263-61429 DEKALB CO GA
D3AT60401 80-60853 WILBUR SMITH & ASSOC SC
E3CG5040199-61091 METRO DADE FL
H3CU60401 44-6081 6 FLA INTERNATIONAL UNIV FL
H3CU60401 56-60893 NORTHERN KENTUCKY UNIV KY
H3CU6040250-61245 RESEARCH TRIANGLE INST NC
H3CU6040285-61 436 WESTERN KY UNIV KY
04,18-86:
04,18/86
05,09,<8£
06,0686
06/19/86
06/20/86
06/20/86
07/09/86
07-15/86
08-07 '86
08'15'86
08-1 5'86
08'21-86
09-0586
09-08/86
05/13,86
06/12/86
08/06 '86
08/1 2 86
09/30/86
04/04/86
04/21/86
04/22/86
06/09-86
04-09-86
04-09 '86
04-10/86
04'10,86
04-17/86
0417,86
04 '18/86
05/13/86
05'13/86
0716,86
07 '17/86
07,'17-'86
07/28/86
09/19,86
09/23,86
09 '24 86
05 '22 '86
07/28/86
07/28/86
07/30-86
08/07 '86
08/07/86
09/02/86
04/1 6/86
06-17/86
04 '09 '86
04'25/86
07 '2 8/86
09 '03 '86
34
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
H3CU6040298-61457
N3GG6040143-60832
N3GG6040169-60897
N3GG6040133-60898
N3GG6040193-6091 8
N3GG6040188-60919
N3GG6040194-60920
N3GG6040196-60922
N3GG6040201-60989
N3GG6040206-61051
N3GG6040207-61052
N3GG6040210-61079
N3GG6040218-61080
N3GG6040223-61115
N3GG6040225-61116
C3FC6050192-60852
C3EC6050216-60969
C3FC6050217-60970
C3EC6050265-61206
C3FC6050266-61207
C3EC6050263-61208
C3FC6050264-61209
C3EC6050281-61231
C3FC6050282-61232
C3EC6050294-61312
C3FC6050295-61313
C3EC6050297-61338
C3FC6050296-61339
C3EC6050304-61340
C3FC6050303-61341
C3EC6050305-61342
C3FC6050306-61343
C3EC6050329-61403
C3FC6050330-61404
C3EC6050327-61405
C3FC6050328-61406
C3EC6050325-61407
C3FC6050326-61408
C3EC6050332-61409
C3FC6050333-61410
C3EC6050334-61413
C3FC6050335-61414
C3EC6050336-61485
C3EG6060115-60836
C3EG6060061-60972
C3FG6060169-61147
C3EG60601 68-61148
C3EG6060170-61151
C3FG6060171-61152
C3EG6060190-61332
C3FG6060191-61333
C3EG6060212-61444
E3DG6060140-60908
H3CU6060134-60849
N3GG6Q60114-60813
N3GG60601 24-60823
N3GG6060130-60845
N3GG6060128-60846
N3GG6060129-60847
N3GG6060133-60850
N3GG6060132-60854
N3GG6060135-60910
N3GG60601 50-61001
C3EG6070096-60848
C3EG6070101-60860
C3EG6070099-60861
C3EG60701 56-61470
C3EG60701 58-61471
C3EG60701 57-61489
C3EG60701 59-61490
C3EG6070160-61567
D3AT6070095-60843
D3AT6070098-60844
H3CU6070154-61438
C3EG6080047-60998
C3EG6080050-61067
C3EG6080054-61114
C3EG6080058-61240
C3EG6080064-61327
C3EG6080071-61392
C3EG6080073-61440
H3BG6080041-60866
H3BG6080045-60978
H3BG6080055-61137
H3BG6080065-61344
H3BG6080066-61345
H3BG6080067-61359
M U R RAY STATE U NIV KY 09' 09/86
KNOXVILLETN 04 11'86
MEMPHIS TN 04,2986
DURHAM NC 04'29'86
KENTUCY DPT AGRI 05/02'86
GAINESVILLE GA 05-0286
GEOLOGICAL SURVEY AL 05'02 86
BIRMINGHAM RPC AL 050286
SO CAROLINA MED UNIV SC 05'20/86
SC LAND RES CON COM COLUMBIASC 06-05-86
GA DEPT NATURAL RES GA 06/05-86
MANATEE CO FL 06.16-86
CUMBERLAND CO NC 06-16/86
HUNTSVILLEAL 0626/86
NC DEPT NAT RESOURCES NC °6 26/86
TOTAL OF REGION 04 - 54
FORT WAYNE (CY 84) IN 0417-86
HAMMOND (CY 84) IN 05 1 5'86
HAMMOND (CY 84) IN 05-15'86
DELTA TWP iCY 85) LANSING Ml 07 21-'86
DEL TA TWP iCY 85) LANSING Ml 07,21-86
PLYMOUTH (CY 85) Ml 07 21/86
PLYMOUTH (CY 85) Ml 072186
BEMIDJI (CY 85) MN 07/23/86
BEMIDJI (CY 85) MN 07'23/86
HAMMOND (CY 85) IN 08'07/86
HAMMOND (CY 85) IN 08'07/86
MICHIGAN CITY (CY 85) IN 08-1486
MICHIGAN CITY (CY 85) IN 0814,86
DECATUR (CY 85) IN 08-14/86
DECATUR (CY 85) IN 081486
PITTSFIELD TWP (CY 85) Ml 08'14'86
PITTSFIELD TWP (CY 85) Ml 0814/86
WILLIAMS BAY (CY 85) Wl 0827-86
W'LLIAMS BAY (CY 85) Wl 08'27'86
AUBURN (CY 85) IN 08<27'86
AUBURN (CY 85) IN 08-27/86
NAPPANEE (CY 85) IN 08 27'86
NAPPANEE (CY 85! IN 08 27/86
VALPARAISO-PORTER CO CY 85 IN 08 27 86
VALPARAISO-PORTER CO CY 85 IN 08 27/86
CAMBRIDGE (CY 85) MN 0828/86
CAMBRIDGE ICY 85) MN 0828-86
ROCHESTER (FY 85) MN 0910/86
TOTAL OF REGION 05 - 57
MELVILLE LA 04/11 86
GUTHRIEOK 05/15/86
BENTONVILLE AR 07/02/86
BENTONVILLE AR 07/02/86
WICHITA FALLS TX 07/02/86
WICHITA FALLS TX 07'02/86
SAN ANTONIO TX 08/13/86
SAN ANTONIO TX 08-13/86
SHREVEPORT LA 09/05/86
TRINITY RIVER AUTHORITY OF TX 04-30/86
SOUTHERN UNIVERSITY LA 04'16/86
LOWER RIO GRANDE VALLEY DEVEL 04'08/86
EDINBURG TX 04-09/86
TULSAOK 04'16/86
NEW MEXICO HEALTH & ENVIRONMEN 04'16/86
LAS CRUCES NM 04/16/86
N M ENERGY & MINERALS DEPT NM 04'16/86
NEW ORLEANS REGIONAL PLANNING 04'17/86
OKLAHOMA STATE DEPT OF HEALTH 04 30/86
NORMAN OK 05/21/86
TOTAL OF REGION 06 = 39
DEPT OF WATER AIR & WASTE IA 04/16/86
LAKE CITY IA 04/17'86
HAYSVILLE KS 04/17'86
OTTAWA KS 09/10/86
HIAWATHA KS 09/10/86
PAOLA KS 09/11/86
GARNETT KS 09'11/86
ANKENY IA 09/30/86
DEVELOPMENT PLANNING & RESEARC 04,16/86
MIDWEST RESEARCH INSTITUTE MO 04/16/86
UNIVERSITY OF KANSAS KS 09/03/86
COLUMBIA FALLS CITY OF MT 05/21/86
DEVILS LAKE CITY OF ND 06/11/86
GRAND JUNCTION CITY OF CO 06/25/86
ENGLEWOOD CITY OF CO 07/28/86
BROOMFIELD CITY OF CO 08/12/86
DURANGO CITY OF CO 08/26/86
MANDAN CITY OF ND 09/03/86
COLORADO STATE UNIV CO 04/18/86
COLORADO UNIV OF CO 05/1 5/86
UTAH UNIV OF UT 06/30/86
MONTANA STATE UNIV MT 08'14/86
UTAH UNIV OF UT 08/14/86
MONTANA UNIV OF MT 08/18/86
TOTAL OF REGION 08 = 27
N3GG6040230-61126
N3GG6040233-61132
N3GG6040234-61134
N3G66040231-61135
N3GG6040253-61239
N3GG6040254-61243
N3GG6040251-61244
N3GG6040270-61316
N3GG6040269-61318
N3GG6040272 61321
N3GG6040286-61434
N3GG6040287-61435
N3GG6040297-61458
N3GG6040313-61513
N3GG6040321-61532
C3FC6050337-61486
C3EC6050323-61487
C3FC6050342-61488
D3DT6050203-61028
D3DG6050283-61348
D3CG6050284-61349
D3CG6050285-61350
D3CG6050286-61351
D3CG6050287-61352
D3CG6050288-61353
N3GC6050191-60851
N3GC6050204-60959
N3GC6050214-60960
N3GC6050211-60971
N3GC6050205-60982
N3GC6050226-60993
N3GC6050228-60994
N3GC6050227-60995
N3GC6050232-61060
N3GC6050244-61169
N3GC6050245-61170
N3GC6050246-61171
N3GC6050262-61175
N3GC6050293-61266
N3GC6050322-61411
N3GC6050324-61412
N3GC6050338-61417
N3GC6050382-61522
N3GC6050321-61523
N3GG6060149-61015
N3CG60601 53-61 021
N3GG6060161-61123
N3GG6060162-61124
N3GG6060163-61125
N3GG6060164-61130
N3GG6060166-61149
N3GG6060167-61150
N3GG6060192-61337
N3GG6060196-61 363
N3GG6060197-61368
N3GG6060203-61394
N3GG6060204-61420
N3GG6060205-61421
N3GG6060206-61426
N3GG6060211-61443
N3GG6060213-61450
N3GG6060214-61468
N3GG6060219-61549
N3GG6070085-60788
N3GG6070102-60862
N3GG6070100-61022
N3GG6070124-61101
N3GG6070125-61128
N3GG6070126-61129
N3GG6070132-61157
N3GG6070147-61357
N3GG6070148-61422
N3GG6070149-61427
N3GG6070155-61445
TOTAL OF REGION 07 - 22
H3BG6080068-61360
N3GG6080042-60881
N3GG6080043-60895
N3GG6080044-60896
N3GG6080046-60981
N3GG6080051-61068
N3GG6080052-61073
N3GG6080057-61189
N3GG6080059-61262
N3GG6080060-61269
N3GG6080063-61271
N3GG6080076-61290
N3GG6080069-61370
N3GG6080070-61377
ST PETERSBURG FL
TENNESSEE (STATE OF) TN
FLORIDA DHRS FL
SARASOTA FL
ESCAMBIA CO FL
POLK CO FL
PINELLAS CO FL
ORANGE CO FL
GEORGIA DEPT AGRI GA
ORLANDO FL
HIGH POINT NC
PASCO COUNTY FL
FLORIDA DHRS FL
ALA DEPT AGRI & IND AL
JACKSON MS
ROCHESTER (FY 85) MN
GAS CITY (CY85I IN
GAS CITY (CY 85) IN
WILLET HOFMANN (FY 80 83)
MCNAMEE PORTER SEELEY Ml
MCNAMEE PORTER SEELEY Ml
MCNAMEE PORTER SEELEY Ml
MCNAMEE PORTER SEELEY Ml
MCNAMEE PORTER SEELEY Ml
MCNAMEE PORTER SEELEY Ml
BLOOMINGTON (CY 84) IN
INDIANA U OF (FY 85)
ROCK ISLAND (FY 85) IL
EVANSVILLE ICY 84) IN
MENOMINEE INC TRIBE (FY 85) Wl
GARY (CY 82) IN
GARY (CY 83) IN
GARY (CY 84) IN
MINNESOTA STATE OF (FY 85)
DES PLAINES (CY 85) IL
HAMILTON CO (CY 84) OH
WINSTED (CY 85) MN
OSHKOSH (CY85) Wl
MICHIGAN DNR (FY 82 83)
MARQUETTE CO (CY 85) Ml
MAHONING CO (CY 84) OH
CUYAHOGA CO (CY 84) OH
LAKEWOOD (CY 85) OH
ILLINOIS DOA (FY 8485)
EL PASO TX
MISSION TX
BROWNWOOD TX
BRYAN TX
SPRINGDALE AR
TEXAS DEPT OF HEALTH TX
RAPIDES AREA PLANNING COMM LA
ARKANSAS STATE PLANT BOARD AR
PALESTINE TX
SHAWNEE OK
CORPUS CHRISTI TX
ABILENE TX
TEXAS DEPT OF AGRICULTURE TX
RUSTON LA
MCALLENTX
AMARILLO TX
FORT WORTH TX
GARLAND TX
STATE OF LOUISIANA LA
COLUMBIA MO
AUGUSTA KS
JEFFERSON CITY MO
MISSOURI DEPT OF NATURAL RESOU
WATERLOO IA
DAVENPORT IAWA
KANSAS BOARD OF AGRICULTURE KS
CAMDENTON MO
DOUGLAS COUNTY NE
DES MOINES IA
LINN COUNTY IA
NO MONTANA COLLEGE MT
NO DAKOTA DEPT OF HEALTH ND
SOUTHERN UTE INDIAN TRIBE CO
UTAH STATE OF UT
CHEYEENE RIVER SOIUX TRIBE SD
COL DEPT OF PUBLIC HEALTH CO
SO DAKOTA DEPT OF HEALTH SD
NO DAKOTA DEPT OF AGRIC ND
MONTANA DEPT OF AGRICULTURE MT
COLORADO DEPT OF AGRICUL CO
MONTROSE CITY OF CO
CROW TRIBE OF INDIANS MT
OGLALA SIOUX TRIBE SD
WESTMINSTER CITY OF CO
09 10-86
09-1086
09-1086
05 30 86
08 1 5 86
08,1586
08-1586
08 15-86
08 15 86
08 1586
04 1786
05 16 86
05 1686
05 15 86
05 16 86
05 20 86
05 20 86
05 20 86
06 10 86
07 11 86
07 11 86
07 11 86
07 11 86
07 30 86
08 28 86
08 28 86
08-2886
09 23 86
09 23 86
05-2986
05 29-86
06i2686
06-2686
06/26 86
06 27 86
07-02 86
07-0286
08 1586
08-18 86
08 19 86
08/26 86
08'29 86
08-29 86
08'29 86
09/05 86
09'09 86
09 10 86
09 25 86
04/01/86
04 18'86
05'29,86
06-26,86
06/27'86
06-27 86
07-03,86
08/18/86
08/29 86
08/29 86
09/05 86
08/18/86
04/22-86
04/28/86
04/28/86
05/15/86
06/11/86
06-12'86
07/16/86
07/30,86
07/31,86
08-01'86
09/24-86
08/20-86
08'22/86
35
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issu
C3EG60901 56-61008
C3EG6090172-61088
I3BG6090129-60904
I3BG6090130-60905
I3BG6090202-61320
N3GG60901 21-60821
N3GG60901 24-60875
N3GG6090125-60880
N3GG6090144-60980
N3GG6090155-61016
N3GG6090160-61030
C3EG6100060-60864
C3EG6100070-60999
C3EG6100069-61000
C3EG6100084-61191
C3EG6100088-61211
C3EG6100096-61401
C3EG6100109-61 558
E3AX6100062-60889
E3CP61 00058-6141 5
H3BG6100091-61241
H3BG6100090-61242
N3GG6100057-60822
N3GG6100061-60865
MALI COUNTY OF HI 052886
HENDERSON CITY OF NV 061786
AMERICAN SAMOA GOVT OF 04 29 86
YAP STATE OF 04 29 86
STATE OF TRUK 08 08 86
TAHOE REG PLANNING AGENCY CA 040986
SANTA BARBARA COUNTY OF CA 042186
HAWAII STATE DEPT OF AGRIC HI 042286
WASHOE CTY DIST HE THDEPT NV 05 1 b 86
CLARK COUNTY OF NV 052986
SAN JOAQUIN COUNTY OF CA 060286
MENAN CITY OF ID 04 1 8 86
COLLEGE PLACE CITY OF WA 0521-86
WATERVIL_E TOWN OF WA 052186
DEPT OF ENVIRON CONSRVN AK 071686
NW AIR PO! LUTION AUTHORITY \A/A 07 2 1 86
ECOLOGY DEPT OF WA 082786
OKANOGAxI CITY OF WA 092686
RESOURCE CONSERVAT ON CO WA 04 25 86
DEPT OF AGRICULTURE OR 082886
WESTERN WASHINGTON UNIV WA 072886
WASHINGTON UNIV OF WA 072886
ANCHORAGE MUNICIPALITY OF AK 04 09 86
YAMHILL COUNTY OF OR 041886
N3GG6090168-61074
N3GG6090173-61110
N3GG609G178 61119
N3GG6090179-61133
N3GG6090185-61190
N3GG6090188-61 210
N3GG6090191-61251
N3GG6090193-61263
N3GG6090194-61 27?
N3GG6090201 61319
N3GG6090204-61328
TOTAL OF REGION 09 - 22
N3GG610C067-60979
N3GG6100071-61032
N3GG61 00075-61062
N3GG61 00076-6108 I
N3GG61 00078-6108'
N3GG61 00079-61109
N3GG61 00080-61120
N3GG61 00082 61177
N3GG61 00089-61 212
N3GG61 00092-61 253
N3GG61 00094-61346
N3GG61 00099-6144 I
N3GG61 00108-61 55''
TRUST TERR OF THE PACIFIC
NEVADA UNIV OF (SYSTEM) NV
COUNCIL OF FRESNO CTY GOVTb CA
SAN JOSE CITY OF CA
MARICOPA ASSN OF GOVTS A7
SANTA ROSA CITY OF CA
SAM LUIS OR.SPO CITY OF CA
FLAGSTAFF CITY OF AZ
INTER-TRIBL COUNCIL OF ARIZ A?
KERN COUNTY OF CA
SAN DIEGO COUNTY OF CA
OREGON STATE OF OR
KITSAP COUNTY OF WA
IDAHO FALLS CITY OF ID
BO SE CITY ID
LUMMI INDIAN BUSINESS COUN WA
YAKIMA CITY OF WA
K NG COUNTY WA
YAKIMA COUNTY OF WA
DEPARTMENT 0 I ANDS ID
JUNEAU CITY & BOROUGH OF AK
SKAGIT COUNTY WA
WATER RESOURCES DEPT OF ID
ADA PLANNING ASSN ID
E3AA6110028-608 79 ASIWPCA
TOTAL OF REGION 10 - 26
04 22 86
TOTAL OF HEADQUARTERS - 1
TOTAL OTHER GRANT AUDITS - 331
05. SUPERFUND GRANT & INTERNAL AUDITS
E5BH5010151-61453 R> COOPERATIVE AGREEMENTS Rl 090886
TOTAI OF REGION 01 -
E5EH6020118-61 546 NJDEP - SLJPERFUND COOPERAT VF 092586
E5BH5020140-61573 NJDEP SUPERFUND COOP AGREE NJ 093086
F5EH602012561576 REGION
TOTA. OF REGION 02 - J
E5EM5040007-60913 ACTIONS AGAiNST RFSPONSIBL E PA 041886
TOTAu OF REGION 04 - '
E5E26050101-61508 SF EHCS CONTRACTS 092386
TOTAL OF REGION 05 1
E5BG6060126-61144 LAN TX 070286 E5BG606012/61257
TOTA_ OF REGION Ob - 2
E5EH4110066-61 534
05EH6110036-60964
P5EH5110019 60942
P5EH511002261094
09 24 86
05 1486
05 08 86
06 1986
P5EH51 10020-61131
P5BG51 10055-61507
P5EH51 10033-61 553
IDITS - 17
08. OTHER CONTRACT AUDITS
D8DT6010141-60926
D8DT60101 50-60955
D8AT6010158-61005
D8AT6010159-61014
D8AT6010171-61050
D8AT6010188-61 095
D8AT6010202-61163
D8AT6010226-61 287
D8DT6010227-61305
D8AT6020108-60827
D8AT6020109-60828
D8CT6020114-60839
D8AT6020124-60938
D8AT6020133-61006
D8DT6020132-61 007
D8AT6020147-61112
FAY SPOFFORD & THORNDIKE INC
UNIVERSAL ENGINEERING CORP MA
META SYSTEMS INC MA
EASTERN RESEARCH GROUP
TRC-ENVIRONMENTAL CONS INC CT
METCALF & EDDY
METCALF & EDDY INC MA
SIGMA RESEARCH CORP MA
f C JORDAN ME
ECOLOGY & ENVIRON-ZONE I NY
ECOLOGY & ENVIRON-ZONE II NY
BURNS & ROE INDUS SERV NJ
LUMMUS CREST INC NJ
ECOLOGY & ENVIRONMENT INC NY
ECOLOGY & ENVIRONMENT INC NY
FRED C HART NY
05,05 86
05 13'86
05 22 86
05 28 86
06 04 86
06 19 86
07 07 86
08 06 86
08 06 86
D8AT60'
D8AT60'
D8AT60'
D8AT60'
D8AT60'
D8AT60'
D8AT601
D8AT60
D8AT60
D8AT60
19
022861306
0234-61369
0238-61382
0239-61383
0240-61384
0245-61396
0246-6139"'
0247 61428
0258-61451
0259-61452
D8DT6020146-61113
D8AT6020172-61334
D8AT6020183-61335
D8CT6020182-61336
D8AT6020188-61 373
D8AT6020194-61469
D8AT6020201-61536
14
E C JORDAN ME
ARTHUR D 1 ITTLE INC MA
STONE & WEBSTER MA
METCALF & EDDY INC MA
CADMUS GROUP MA
METCALF & EDDY MA
ENV RESEARCH & TECHNOLOGY MA
ENERGY & ENVIRONMENTAI ENG Mf-
ARTHUR D LITTI E INC MA
STONE & WEBSTER ENG CORP MA
BURNS & ROE NJ
GFRAGHTY & MILLER NY
ECOLOGY & ENVIRONMENT NY
FRED C HART NY
ASSOCIATED WEATHER SERVICES N
SYRACUSE RESEARCH CORP NV
SYRACUSE RESEARCH CORP NY
36
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
D8AT6030174-60802
D8AT6030175-60803
D8AT6030193-60930
D8CT6030194-60933
D8AT6030195-60934
D8DT6030196-60935
D8DT6030197-60936
D8AT6030198-60937
D8AT6030204-61009
D8AT6030205-61010
D8AT6030206-61011
D8AT6030207-61012
D8AT6030208-61013
D8DT6030210-61040
D8AT6030211-61041
D8DT6030212-61042
D8CT6030213-61043
D8DT6030214-61044
D8DT603021 5-61045
D8AT6030216-61 046
D8AT6030217-61047
D8AT6030218-61048
D8AT6030229-61158
D8DT6030230-61159
D8CT6030231-61160
D8AT6030232-61161
D8AT6030233-61162
D8DT6030238-61179
D8DT6030239-61180
D8AT6030240-61181
D8AT6030241-61182
D8DT6030242-61183
D8DT6030249-61201
D8DT6030250-61202
D8CT6030251-61203
D8CT6030252-61204
D8CT6030253-61205
D8AT6030254-61215
D8DT6030255-61216
D8AT6030256-61217
D8AT6030257-61218
D8DT6030258-61219
D8CT6030259-61220
D8AT6030260-61221
D8CT6030261-61222
D8AT60401 57-60799
D8CT6040203-60991
D8CT6040222-61090
D8AT6040229-61103
D8AT6040235-61141
D8AT6040244-61186
D8AT6040257-61227
D8AT6040256-61228
D8AT6040261-61267
D8AT6040262-61268
D8AT6040281-61375
D8AT6040268-61379
D8CT6050189-60831
D8CT6050190-60833
D8DT6050208-60928
D8AT6050207-60949
D8AT6050212-61027
D8BT6050213-61029
D8AT6050243-61155
D8AT6050242-61156
SOBOTKA COMPANY 04/04/86
ICF 04/04/86
DYNAMAC CORP 05/06/86
GKY ASSOCIATES 05/06/86
NUS CORP 05/06/86
JACA CORP 05/06/86
NATIONAL ANALYSTS PA 05-06/86
MERIDIAN RESEARCH MD 05'06'86
SRA TECH INC VA 05/28/86
MATHTECH INC NJ 05/28/86
C C JOHNSON ASSOCIATES MD 05/28/86
ICF TECHNOLOGY DC 05/27,86
POLICY PLAN EVALUATION INC 05/28'86
SYSTEX INC MD 06-03/86
WADE MILLER ASSOC VA 06/03/86
CALCULON CORP PA 06/03-86
JSC&F INC DC 06,03/86
TRACOR-JITCO INC MD 06/03/86
FRANKLIN RESEARCH CENTER PA 06,03 86
ICF TECHNOLOGY DC 06'03,86
GENERAL SCIENCE CORP MD 06,03,86
RESOURCE APPLICATIONS INC VA 06/03-86
Cl ENENT ASSOCIATES-VA 07 07-86
JACA CORPORATION-PA 07 07-86
AUTOMATED SCIENCES GROUP-MD 07-07/86
EA ENGIN-SCIENCE-TECH INC -MD 07 07 86
CC JOHNSON & ASSOCIATES-MD 07,0786
PEAT MARWICK MITCHELL & CO-DC 07'15'86
EBON RESEARCH SYSTEM INC-DC 07,15/86
ENVIRON CORP-DC 0715,86
NUS CORP-MD 071586
ROY F WESTON INC-PA 0715,86
NUS CORPORATION-MD 07-2186
ENERGY & ENVIRO ANALYSIS INCVA 07,21,86
GKY & ASSOC INCORP-VA 0721/86
GKY & ASSOC INCORP-VA 07 21 86
VERSAR INC-VA 07,21 86
TECHNICAL RESOURCES INC MD 07'22'86
PROGRAM RESOURCES INC-MD 07 22'86
JACK FAUCETT ASSOC-MD 0722-86
VJ CICCONE & ASSOC INCORP-VA 072286
SYSTEMS & APPLIED SCIENCES-VA 07 22-86
EBON RESEARCH SYSTEMS-DC 07-22 86
JACK FAUCETT ASSOC 07 22'86
EBON RESEARCH SYSTEMS-DC 07 22 86
D8AT6030262-61223
D8AT6030263-61224
D8CT6030264-61225
D8AT6030265-61226
D8AT6030276-61288
D8AT6030277-61289
D8AT6030279-61291
D8AT6030280-61292
D8AT6030281-61293
D8DT6030282-61294
D8DT6030283-61295
D8AT6030284-61296
D8AT6030285-61297
D8AT6030286-61298
D8CT6030287-61299
D8AT6030288-61300
D8DT6030289-61301
D8DT6030290-61302
D8AT6030291-61303
D8AT6030300-61459
D8AT6030301-61460
D8AT6030302-61461
D8AT6030303-61462
D8AT6030304-61463
D8AT6030305-61464
D8AT6030306-61465
D8AT6030307-61466
D8AT6030308-61467
D8AT6030309-61475
D8AT6030310-61476
D8AT603031 5-61495
D8CT6030316-61496
D8AT6030318-61515
D8AT6030319-61516
D8AT6030326-61538
D8AT6030327-61539
D8AT6030328-61540
D8AT6030329-61541
D8AT6030330-61542
D8AT6030331-61543
D8AT6030332-61544
D8AT6030333-61545
D8AT6030335-61570
D8AT6030336-61571
D8AT6030337-61572
TOTAL OF REGION 03 = 90
WILBUR SMITH & ASSOC SC
ENVIRONMENTAL SC & ENGR FL
ENTROPY ENVIRONMENTALIST NC
NORTHROP SERVICES NC
NORTHROP SERVICES NC
NORTHROP SERVICES NC
NORTHROP SERVICES NC
NORTHROP SERVICES NC
NORTHROP SVCS NC
NORTHROP SVCS NC
ENTROPY ENVIRONMENTALIST NC
ENVIRONMENTAL SC & ENGR FL
04 03 86
05-2086
06/18/86
0623,86
07-02-86
07 1 5/86
07 23 86
072386
07 31 86
07 31/86
0821 86
08 22/86
D8AT6040273-61380
D8AT6040267-61388
D8AT6040295-61477
D8AT6040296-61478
D8AT6040288-61480
D8AT6040291-61481
D8AT6040283-61482
D8AT6040292-61484
D8AT6040320-61533
H8AT6040159-60807
H8AT6040299-61479
H8AT6040284-61483
H8AT6040314-61512
TOTAL OF REGION 04 = 25
REXNORD INC (MILWAUKEE) Wl 0411,86
REXNORD INC (MILWAUKEE) Wl 0411/86
REXNORD INC MILWAUKEE FY 84 85 05-05-86
LIFE SYSTEMS INC CLEVELAND OH 051286
BABCOCK & WILCOX BARBERTON OH 05-30,86
LLINOIS U OF (URBANA) 06,0286
BMI COl UMBLS OH 07'02,86
BABCOCK & WILCOX BARBERTON OH 070286
D8AT6050291-61274
D8AT6050290-61275
D8AT6050292-61310
D8AT6050289-61311
D8AT6050341-61455
D8AT6050379-61524
D8AT6050378-61525
P8AT6050247-61509
ROY F WESTON INC-PA
BREGMEN & CO INC-MD
EBON RESEARCH SYSTEMS-DC
MERIDAN RESEARCH INCORP-MD
AEPCO INC MD
CADMUS GROUP INC-VA
PEER CONSULTANTS MD
PROGRAM RESOURCES INC-MD
WESTAT INCORPORATED-MD
CENTEC CORP-VA
HORIZON SYSTEMS COPR-VA
ICF INCORPORATED-DC
BAKERTSC INCORP-PA
DYNAMAC CORP-MD
EBON RESEARCH SYSTEM-DC
ICF INCORPORATED-DC
INTEGRATED MICROCOMPUTERS-MD
PA ELECTRIC COMPANY-PA
ICF TECHNOLOGY-DC
BOOZ-ALLEN & HAMILTON INC - MD
DYNAMAC CORP - MD
ICF TECHNOLOGY- DC
MACRO SYSTEMS INCORP - MD
TECHNICAL RESOURCES INCORP-MD
THE EARTH TECHNOLOGY CORP - VA
GEOTRANS INCORP - VA
BIONETICS CORP - VA
BOOZ-ALLEN & HAMILTON INC - MD
BOOZ ALLEN & HAMILTON INC - MD
DYNAMAC CORP MD
LABAT-ANDERSON INC - VA
BETZ CONVERSE MURDOCH INC - PA
NATIONAL FOOD PROCESS ASSOC-DC
COMPUTER SCIENCES CORP - VA
GEOMET TECHNOLOGIES INC - MD
NAHB RESEARCH FOUNDATION - MD
PLANNING RESEARCH CORP - VA
DYNAMAC CORPORATION - MD
BAKER -TSA INCORPORATED - PA
DESMATICS INCORP PA
VIAR & CO - VA
DYNAMAC CORP - MD
ROY F WESTON INC - PA
PROGRAM RESOURCES INC - MD
CRC SYSTEMS INCORP - VA
AWARE INC NASHVILLE TN
ENVIRONMENTAL SYSTEMS CORP TN
PE LAMOREAUX AL
NORTHROP SVCS NC
ENVIRONMENTAL SC & ENGR FL
EBON RESEARCH SYSTEMS FL
WATER & AIR RESEARCH INC FL
NORTHROP SEVICES RTP NC
NORTHROP SERVICES NC
RESEARCH TRINAGLE INST NC
RESEARCH TRIANGLE INST NC
RESEARCH TRIANGLE INST NC
RESEARCH TRIANGLE INST NC
BMI COLUMBUS OH
BABCOCK & WILCOX ALLIANCE OH
AUTO TESTING LAB E LIBERTY OH
LIFE SYSTEMS INC CLEVELAND OH
BMI COLUMBUS OH
IT RES INST CHICAGO IL
MCNAMEE PORTER SEELEY Ml
OH MATERIALS
07,2286
07'2286
07,22 86
07-2286
0806,86
08 06 86
08,06,86
08 06 86
08-06 86
08/06 86
08 06 86
08/06,86
08,0686
08-06 86
08,0686
08-06 86
08/06 86
08/06 86
08 06,86
09/09'86
09 09 86
09 09 86
09-09 86
09-09 86
09 1086
09 10,86
09 1086
09 1086
09 1086
09 15 86
09 1 5 86
09 19 86
09 19 86
09 24 86
09 24 86
09 24 86
09 24 86
09 24 86
09 24 86
09 24 86
09 24 86
09 30 86
09 30 86
09 30 86
08 22 86
08 25 86
09 1086
09 1086
09 1086
09 10 86
09 10 86
09 10 86
09 24 86
04 07 86
09 1086
09 10,86
09 19 86
TOTAL OF REGION 05-16
D8CT6060131-60855
D8AT6060141-60912
D8AT6060142-61058
D8AT6060178-61258
D8AT6060180-61 259
D8AT6060179-61260
D8AT6060181-61264
D8CT6070086-60792
D8CT6070087-60793
D8CT6070088-60794
D8AT6070108-60903
D8AT6070109-60941
D8AT60701 23-61111
D8AT6090116-60811
D8AT6090117-6081 2
D8AT6090122-60835
D8AT6090123-60840
D8BT60901 27-60887
D8AT60901 28-60894
WALK HAYDEL & ASSOCIATES LA 04-17-86
GULF SOUTH RESEARCH INSTITUTE 04,30-86
K S CRUMP & CO LA 06,06/86
KEN E DAVIS TX 07 30/86
ENGINEERING ENTERPRISES INC O 0730/86
KW BROWN & ASSOCIATES INCTX 07-30/86
FELIX & ASSOCIATES INC OK 07-3086
D8AT6060182-61 265
D8AT6060186-61 276
D8AT6060187-61 277
D8AT6060188-61 329
D8AT6060189-61366
D8AT6060194-61367
D8AT6060217-61497
TOTAL OF REGION 06 - 14
MIDWEST RESEARCH INSTITUTE MO 04/02,86
MIDWEST RESEARCH INSTITUTE MO 04 02,86
MIDWEST RESEARCH INSTITUTE MO 04,02 86
DEVELOPMENT PLANNING & RES KS 04-29/86
MIDWEST RESEARCH INSTITUTE MO 05-08,86
BLACK & VEATCH AE MO 06,24/86
TETRA TECH INC PASADENA CA 04,0786
TETRA TECH INC PASADENA CA 040786
TETRA TECH INC PASADENA CA 04 1 1 86
SRI INTERNATIONAL MENLO PARK C 04,16,86
ROCKWELLINTL ROCKETDYNE DIV CA 04 24 86
ACUREX CORPORATION MTN VIEW CA 04,28 86
D8AT6070133-
D8AT6070140-
D8AT6070139-
D8BT6070144-
D8AT6070146-
H8CT6070122
61145
61235
61237
61325
61365
61102
TOTAL OF REGION 07-12
D8AT6090133-60916
D8AT6090134-60917
D8AT6090136-60939
D8AT6090135-60940
D8CT6090145-60966
D8AT6090146-60974
K W BROWN & ASSOCIATES TX 073086
RADIAN CORPORATION TX 080486
RADIAN CORPORATION TX 08 04 86
RADIAN CORPORATION TX 08 12 86
REED & ASSOCIATES INCTX 081986
EG&G AUTOMOTIVE RESEARCH INC T 08 19 86
JORDAN-DELAURENTI 091686
DEVELOPMENT PLANNING & RSCH KS 07 02 86
MIDWEST RESEARCH INSTITUTE MO 07 25 86
FRANKLILN ASSOCIATES LTD KS 072586
HOWARD NEEDLES TAMMEN & BERG M 08 12 86
MIDWEST RESEARCH INSTITUTE MO 08 19 86
IOWA STATE UNIVERSITY IA 062386
TETRA TECH INC PASADENA CA
SCIENCE APPLICATIONS INTL CA
ENERGY & ENV RESEARCH CORP CA
BROWN & CALDWELL SEATTLE WA
TRW INC SPACE & TECH GROUP CA
ENV MONITORING & SVCS INC CA
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report
D8AT6090147-6097 5
D8AT6090148-60976
D8AT6090149-60977
D8AT6090154-60988
D8AT6090157-61017
D8AT6090158-61018
D8AT6090159-61019
D8CT6090161-61031
D8AT6090165-61056
D8AT6090166-61061
D8AT6090169-61082
D8AT6090180-61140
D8AT6090181-61153
D8DT6090182-61165
D8AT6090183-61168
D8AT6090184-61173
D8AT6090186-61199
D8AT6090187-61200
D8AT6090189-61230
D8AT6090190-61236
D8AT6090192-61 252
ENV MONITORING & SVCS INC CA 05/1 5/86
ENV MONITORING & SVCS INC CA 05/15/86
ENV MONITORING & SVCS INC CA 05/1 5/86
ENV MONITORING & SVCS INC CA 05/19/86
TETRA TECH INC PASADENA CA 05/29/86
JACOBS ENG GROUP INC CA 05/29/86
JACOBS ENG GROUP INC CA 05/29/86
SCIENCE APPLICATIONS INTL CA 06/02/86
TETRA ECH INC PASADENA CA 06/06/86
ACUREX CORPORATION MTN VIEW CA 06/10/86
JACOBS ENG GROUP INC CA 06/16/86
ACUREX CORP MTN VIEW CA 07/01/86
AEROVIRONMENT INC MONROVIA CA 07/02/86
DAMES AND MOORE LOS ANGELES CA 07/08/86
MED TOX ASSO INC TUSTIN CA 07/10/86
GEO/RESOURCE CONSULTANTS CA 07/11 '86
SCS ENGINEERS LONG BEACH CA 07/17/86
DAMES & MOORE LOS ANGELES CA 07/17/86
SRI INTERNATIONAL CA 07/23/86
EARTH TECH CORP LONG BEACH CA 07/25/86
JACOBS ENG GROUP INC CA 07/29/86
D8AT6100068-60965
D8AT6100100-61472
D8AT6100101-61473
TOTAL OF REGION 09 =
ENVIRONMENTAL TOXICOLGY INT WA 05/14/86
NORTHWEST SYSTEMS RESEARCH WA 09/10/86
NORTHWEST SYSTEMS RESEARCH WA 09/10/86
D8AT60901 95-61 273
D8AT6090 196-61 278
D8AT60901 97-61 279
D8AT60901 98-61 280
D8AT6090200-61304
D8AT6090205-61330
D8AT6090206-61356
D8AT609021 7-61 386
D8AT60902 18-6 1387
D8AT609021 9-61 399
D8AT6090220-61400
D8AT6090221-61425
D8BM6090214-61430
D8BM6090222-61431
D8AM6090223-61447
D8AT6090224-61448
D8AT6090225-61474
D8AT6090227-61493
D8AT6090228-61494
D8AT6090229-61535
D8DT6090230-61555
D8DT6090231-61556
H8AT60902 15-61 378
H8AT609021 6-61 385
57
E8AX61 00064-60968
E8AS61 00074-61 065
ENGINEERING-SCIENCE INC CA
C L STEGALL COMPANY CA
SCIENCE APPLICATIONS INTL CA
SYSTEMS APPLICATIONS INC CA
ENV MONITORING & SERVICES CA
SCIENCE APPLICATIONS INTL CA
ENERGY & ENV RESEARCH CORP CA
SCIENCE APPLICATIONS INTL CA
TETRA TECH INC CA
TETRA TECH INC CA
ZONGE ENG & RSRCH ORG INC AZ
GLOBAL GEOCHEM CORP CA
INTL TECHNOLOGY CORP CA
INTL TECHNOLOGY CORP CA
INTL TECHNOLOGY CORP CA
TRACER RESEARCH CORP AZ
INTL TECHNOLOGY CORP CA
JACOBS ENG GROUP INC CA
TETRA TECH INC CA
JACOBS ENG GROUP INC CA
MATRECON INC CA
MATRECON INC CA
UNIVERSITY OF NEVADA NV
DESERT RESEARCH INSTITUTE NV
CH2M HILL INC OR
CH2M HILL INC OR
OJ
Oi
Oi
Oi
Oi
Oi
Oi
Oi
Oi
Oi
Oi
Oi
0!
Oi
Oi
0!
Oi
0!
0!
0!
0!
0!
o:
0!
0
0
TOTAL OF REGION 10 = 5
TOTAL OTHER CONTRACT AUDITS = 252
09. SUPERFUND CONTRACTS
E9AT6040128-60929 ENSCO(SUB TO HAZTECH) PEAK SIT
E9DT6040024-61072 HAZ TECH NC
E9CT5040269-61142 HAZTECH INC
E9CT5040230-61143 HAZ TECH (PEPPER STEEL) 80 FL
05/06/86
06/12/86
07/02/86
07/02/86
TOTAL OF REGION 04 = 9
E9AT6040221-61238
E9AT6040240-61317
E9AT6040264-61381
E9CT6040200-61517
E9CT5040044-61561
HAZTECH GA
HAZTECH (EG&G IDAHO) GA
IT CORPORATION TN
HAZTECH ATLANTA GA
HAZTECH (SMITH FARM SITE) KY
E9AT60501 28-61 358 MAECORP INC (MID-AMERICA E/S) 08/18/86
TOTAL OF REGION 05 = 2
E9DT60601 59-61 326 LOCKWOOD 08/12/86
TOTAL OF REGION 06 = 2
E9AT6050320-61510 MAECORP INC
E9AT6060165-61376 SUNBELT ENVIRONMENT MAN INC OK 0
E9CT6070083-61256 CORNEJO & SONS
07/30/86
TOTAL OF REGION 07 = 1
D9CT6090199-61285 UNITEK ENV SERVICES INC HI
08/05/86 E9AT6090177-61416 CROSBY & OVERTON LONG BEACH CA OI
TOTAL OF REGION 09 = 2
E9CT5100077-60789 ENVIRON EMERG SERV PORTLAND OR 04/01/86
E9AT6100081-61398 CANONIE ENGINEERING INC IN 08/27/86
E9AT6100077-61418 RIEDEL ENVIRON SERVI ES OR 09/05/86
E9CT5100027-61433
E9AT6100098-61502
P9DT6100056-60814
P9BT5100067-61092
TOTAL OF REGION 10 = 7
TOTAL SUPERFUND CONTRACTS = 23
TOTAL AUDITS = 788
ENVIRON EMERG SERV PORTLAND OR 0!
CH2M HILL OR 0!
CH2M HILL CORVALLIS OR 0-
CH2M HILL - CORVALLIS OR OI
38
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U.S. Environmental Protection Agency
Region 5, Library (5PL-16)
230 S. Dearborn Street, Room 1670
Chicago, IL 60604
-------
ntal protection Agency
U.S. Environmental *£° .
Chicago,
-------
If you know or suspect
• •
FRAUD,
WASTE OR
ABUSE
call the
INSPECTOR GENERAL
HOTLINE
• INFORMATION IS CONFIDENTIAL
• CALLER CAN BE ANONYMOUS
800 424-4000 or 202 382-4977
US. ENVIRONMENTAL PROTECTION AGENCY • OFFICE OF THE INSPECTOR GENERAL • 401 M STREET S.W.. WASHINGTON. O.C. 20460
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